Job Description

🌍 About the Company

The client is a Bank of Lithuania-licensed electronic money institution providing electronic money and payment services across European markets. Its infrastructure supports crowdfunding platforms and enables payment execution, card transactions, money remittance and other regulated financial services. The company is now expanding from its established crowdfunding focus towards a broader EMI model, including SEPA and card services. With international ownership and an evolving product portfolio, it is strengthening its governance, financial crime controls and regulatory capabilities.

💼 About the Role

As MLRO, you will lead the independent second-line framework covering AML/CFT, sanctions, fraud risk and control quality. Reporting administratively to the CEO and functionally to the Management Board, you will oversee the AML Unit and provide credible challenge across the business.

During the company’s current growth stage, your remit will be broader than a traditional MLRO position. You will shape the overall financial crime control environment, lead regulatory engagement and ensure the company is prepared for inspections, audits and the risks arising from new EMI products.

🔍 Responsibilities

• Own and continuously strengthen the company’s AML/CFT, sanctions and fraud risk framework, including policies, procedures and control standards;
• Lead the enterprise-wide ML/TF risk assessment and update it when products, customer segments, markets, systems or delivery channels change;
• Monitor compliance with the approved risk appetite and challenge decisions involving higher-risk customers, geographies, products and transaction patterns;
• Define CDD, KYC, KYB and ongoing monitoring requirements while independently assessing the effectiveness and quality of their implementation;
• Review escalated suspicious activity, make documented decisions on transaction restrictions and submit required reports to the FCIS/FNTT;
• Oversee sanctions screening, escalation and investigation controls, including potential circumvention cases and decisions concerning asset freezes;
• Provide second-line oversight of fraud risks and controls until the organisation establishes a separate specialist function;
• Act as the primary AML/CFT and sanctions contact for the Bank of Lithuania, FCIS/FNTT and other competent authorities;
• Lead the AML Unit, set priorities and ensure effective delivery across KYC/KYB, monitoring and related financial crime activities;
• Coordinate Bank of Lithuania inspections, internal and external audits, regulatory remediation, employee training and management reporting.

🎓 Requirements

• At least 3 years of AML/CFT experience within financial services or another regulated environment;
• A university degree in law, economics, finance, business administration or a related field;
• Strong knowledge of Lithuanian and EU AML/CFT legislation, international sanctions requirements and relevant regulatory guidance;
• Practical understanding of fraud risk, transaction monitoring, control testing and the wider risk environment of an electronic money institution;
• Experience assessing monetary operations, customer activity and transaction patterns to reach clear, well-documented risk decisions;
• The fitness, propriety and impeccable reputation required of a key function holder;
• Confidence to act independently, challenge commercial decisions and escalate material concerns to senior management or the Management Board;
• Professional proficiency in English, both written and spoken.

Nice to Have

• Previous experience as an MLRO, Deputy MLRO, Sanctions Officer or senior financial crime compliance professional;
• Experience within an EMI, payment institution, bank, crowdfunding platform or lending business;
• An ACAMS, ICA or other recognised AML/CFT qualification;
• Lithuanian language proficiency and experience communicating directly with Lithuanian supervisory authorities.

🤝 Key Competencies

• Independent judgement and the confidence to make accountable decisions;
• Leadership responsibility and the ability to guide a specialist AML team;
• Clear regulatory communication and senior stakeholder management skills;
• A methodical approach to investigations, control assessments and remediation;
• The resilience to uphold compliance standards when commercial priorities create pressure.

✨ The Employer Offers

• A key regulated position with direct access to the CEO and Management Board;
• Leadership of an established AML Unit and influence over its future structure;
• A broad mandate spanning AML/CFT, sanctions, fraud prevention and control quality;
• Authority to challenge business decisions, restrict suspicious activity and initiate sanctions-related measures;
• A hybrid working model with flexible hours;
• Support for professional training and certifications through a learning budget;
• International exposure across payments, electronic money, crowdfunding, SEPA and card services;
• Modern work equipment.

This role suits a financial crime professional who wants genuine independence, team leadership and a clear mandate to influence regulated business decisions. Apply now to shape the control framework behind the company’s next stage as a full-service EMI.