Senior Manager - Global KYC Policy & Governance
Location: Madrid, Spain
Type: Full-time
We are seeking an experienced professional to lead and strengthen our global Client Due Diligence (CDD), Know Your Customer (KYC), and regulatory compliance framework. The successful candidate should possess deep expertise in Global and Regional KYC policies, client lifecycle governance and regulatory compliance across multiple jurisdictions.
This role requires a strong understanding of regulatory requirements, financial crime controls, and policy implementation, coupled with extensive experience in managing KYC programs, interpreting regulatory changes, and driving operational excellence across global teams.
Responsibilities
1. Global and Regional KYC Policy
Draft, review, maintain, and enhance global and regional KYC policies, procedures, standards, control requirements, desktop guides, and operating manuals.
Interpret global minimum standards and identify country or regional nuances applicable to the UK, Spain, wider EMEA, and other relevant jurisdictions.
Perform policy gap assessments arising from regulatory change, audit findings, quality reviews, control failures, or operational feedback.
Manage policy governance activities including stakeholder consultation, approvals, version control, implementation planning, communication, and periodic review.
Provide practical advisory support on policy interpretation, exceptions, escalations, risk acceptance, and documentation requirements.
Translate complex regulatory obligations into concise, clear, and operationally workable procedures for first- and second-line teams.
2. Complex Entity and Beneficial Ownership Advisory
Provide expertise on complex legal entity types, including Special Purpose Vehicles (SPVs), trusts, foundations, funds, partnerships, holding companies, private investment vehicles, family offices, and financial institutions.
Assess ownership and control chains to identify ultimate beneficial owners, controllers, board of directors, and authorized signatories.
Define documentary and verification standards for layered, cross-border, nominee, or otherwise complex structures.
Advise on CDD and EDD requirements for higher-risk customers, politically exposed persons, adverse media, sanctions exposure, and higher-risk jurisdictions.
Develop practical decision trees and training material to improve consistency in complex entity reviews.
3. Regulatory Policy and Change
Monitor, assess, and support implementation of regulatory and industry developments affecting KYC, AML/CTF, sanctions, customer due diligence, beneficial ownership, and tax transparency.
Apply practical knowledge of relevant frameworks such as UK and EU AML requirements, FCA expectations, JMLSG guidance, Spanish AML requirements, FATCA, CRS, MiFID II, and EMIR, where relevant to client onboarding and lifecycle management.
Complete regulatory change impact assessments covering policy, process, control, data, technology and training
Support regulatory reviews, internal audit, compliance testing, quality assurance, remediation program, and closure of management actions.
Maintain a clear audit trail demonstrating how regulatory obligations have been interpreted and embedded.
4. KYC Platform Testing and Transformation
Provide policy SME input into KYC / Client Lifecycle Management platforms such as Fenergo, Pega, or comparable workflow and case-management systems.
Translate policy requirements into business requirements, user stories, decision rules, customer-risk logic, mandatory data fields, document requirements, workflow steps, and control points.
Validate that platform configuration accurately reflects entity type, jurisdiction, product, risk rating, screening, CDD/EDD, periodic review, and escalation requirements.
Partner with Product Owners, Business Analysts, Technology, Operations, and Compliance to triage defects and deliver sustainable remediation.
Identify opportunities to improve automation, data quality, operational efficiency, user experience, controls, and management information.
5. Governance, Controls and Stakeholder Management
Act as a trusted KYC policy adviser to Compliance, Financial Crime, Legal, Operations, Front Office, Tax, Risk, Audit, and Technology stakeholders.
Lead or contribute to policy forums, working groups, design authorities, governance committees, testing checkpoints, and implementation-readiness reviews.
Produce high-quality decks, recommendations, risk assessments, and executive updates for senior stakeholders.
Develop and deliver training on policy changes, complex entities, regulatory requirements, and system-enabled KYC processes.
Coach colleagues, review deliverables, and promote consistent risk-based decision-making across locations and business lines.
Monitor implementation of effectiveness using issues, testing results, quality metrics, KRIs, audit observations, and user feedback.
Eligibility Requirements
Demonstrable experience drafting KYC policies, procedures, standards, and operational guidance.
Strong understanding of global KYC standards and regional / local variations.
Practical expertise with SPVs, trusts, foundations, beneficial ownership, CDD, and EDD.
Regulatory policy and change-management experience.
Hands-on experience testing Fenergo, Pega, or a comparable KYC / CLM platform.
Strong written communication, analysis, judgement, and stakeholder-influencing skills.
Ability to operate effectively across global, multidisciplinary teams
Preferred Requirements
ACAMS / CAMS certification.
Certified Fraud Examiner (CFE).
ICA Diploma in AML, Financial Crime Prevention, or Compliance.
Experience in a global bank, corporate and investment bank, private bank, or large financial institution.
Knowledge of UK and Spanish / EU regulatory environments.
Experience with UAT governance, requirements traceability, defect management, and implementation assurance.
Spanish language capability for a Madrid-based appointment; additional European languages are beneficial.
Exposure to Agile delivery, product ownership, or large-scale KYC remediation and transformation programmes.
Bachelor's degree in Finance, Law, Business, Economics, Risk Management, or a related discipline; a postgraduate qualification is desirable.
ACAMS / CAMS and CFE certifications are preferred. ICA or other recognized AML, compliance, fraud, risk, or testing credentials would also be advantageous.
How to Apply
About eClerx
eClerx is a leading provider of productized services, bringing together people, technology and domain expertise to amplify business results.
The firm provides business process management, automation, and analytics services to a number of Fortune 2000 enterprises, including some of the world’s leading financial services, communications, retail, fashion, media & entertainment, manufacturing, travel & leisure, and technology companies. Incorporated in 2000, eClerx is traded on both the Bombay and National Stock Exchanges of India. The firm employs more than 19,000 people across Australia, Canada, France, Germany, Switzerland, Egypt. India, Italy, Netherlands, Peru, Philippines, Singapore, Thailand, the UK, and the USA.
For more information, visit www.eclerx.com
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eClerx is an Equal Opportunity Employer. All qualified applicants will receive consideration for employment without regard to race, color, religion, sex, national origin, disability or protected veteran status, or any other legally protected basis, in accordance with applicable law. We are also committed to protecting and safeguarding your personal data. Please find our policy here
eClerx is a productized services company, bringing together people, technology and domain expertise to amplify business results. Our mission is to set the benchmark for client service and success in our industry. Our vision is to be the innovation partner of choice for technology, data analytics and process management services.
