KYC & KYB Due Diligence Analyst - Partner Onboarding

About The Role

Key Responsibilities

• *Partner due diligence*
• Lead end-to-end KYC and KYB due diligence on prospective partners across the Group's gaming and payments ecosystem, including payment service providers, acquirers, EMIs, game studios and aggregators, platform suppliers, affiliates and affiliate networks, marketing partners and B2B counterparties.
• Conduct identity verification, corporate structure analysis, and ultimate beneficial ownership (UBO) identification down to the natural person level, including for complex multi-jurisdictional structures involving offshore vehicles, trusts, foundations, and multi-tiered holding arrangements
• Perform sanctions, politically exposed person (PEP), and adverse media screening using the Group's screening tools (e.g. ComplyAdvantage, World-Check, LexisNexis, Sumsub or equivalent), with appropriate handling of name-match resolution and false positives
• **Assess source of funds and source of wealth documentation for partner principals,** applying enhanced due diligence (EDD) where indicated by the risk profile, jurisdiction, sector or transaction structure
• Validate the regulatory standing of counterparties in each relevant jurisdiction
• Prepare written due diligence reports and risk assessments calibrated to the materiality of the relationship, with clear recommendations on whether to onboard, decline, or onboard with conditions
• ***Risk and red flag investigation***
• Investigate and resolve red flags, including unusual ownership structures, regulator
• enforcement history, adverse media, sanctions nexus, jurisdictions of concern, and
• indicators of shell or front company arrangements
• Identify financial crime typologies relevant to the igaming and payments sector,
• including affiliate fraud, payment laundering schemes, and chargeback abuse
• Escalate suspicious activity or financial crime indicators promptly to the MLRO in
• accordance with the Group's escalation framework
• ***Ongoing monitoring***
• Conduct periodic refreshes of partner due diligence in line with the Group's risk-based
• review schedule
• Monitor changes in partner circumstances - ownership changes, key person changes,
• sanctions designations, adverse media, regulator action, licence variations or revocations
• and trigger reassessment where required
• Maintain accurate, complete and audit-ready due diligence records in the Group's systems
• ***Regulatory and audit support***
• Support the Compliance team in responding to regulator queries, audits and inspections
• relating to partner onboarding records, including from the ADGM Financial Services
• Regulatory Authority (FSRA), partner banks and acquirers
• Support diligence requests from payment partners, particularly card scheme acquirers
• (Visa, Mastercard) and EMIs, where the Group is itself the subject of partner due
• diligence
• Contribute to the Group's annual financial crime risk assessment and partner risk register
• ***Continuous improvement and stakeholder engagement***
• Contribute to the continuous improvement of onboarding policies, procedures and
• tooling, including identifying opportunities to streamline workflows without
• compromising risk standards
• Liaise with Legal, Commercial, Finance, Treasury, Payments and Operations teams to
• ensure onboarding decisions are commercially aware, operationally workable, and
• consistent with regulatory expectations Provide training and informal coaching to business teams on KYC and KYB
• requirements, jurisdiction-specific obligations, and red flags
• Regulatory framework knowledge
• The role requires working knowledge of the following frameworks across the Group's principal
• jurisdictions:
• *ADGM (UAE)*
• ADGM FSRA Anti-Money Laundering and Sanctions Rules and Guidance (AML

Rulebook)

• UAE Federal Decree-Law No. 20 of 2018 on AML/CFT and its Executive Regulation
• UAE Cabinet Decision No. 58 of 2020 on the Regulation of Beneficial Ownership Procedures
• Sanctions obligations under UAE federal law and applicable UN/UK/EU/US sanctions regimes
• UAE Federal Decree-Law No. 45 of 2021 on Personal Data Protection (insofar as it interacts with onboarding data)
• ***United Kingdom***
• The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017), as amended
• The Proceeds of Crime Act 2002 (POCA) and Terrorism Act 2000 reporting obligations
• UK Sanctions and Anti-Money Laundering Act 2018 and OFSI sanctions regime
• FCA financial crime guidance where applicable to the Group's payments activities (FCG, FCG sourcebook)
• ***European Union***
• The EU AML framework, including the Fourth, Fifth and Sixth AML Directives
• (4AMLD/5AMLD/6AMLD) as transposed in EU Member States, and the new EU AML
• Regulation and AMLA framework as it comes into effect
• EU sanctions regime under Council Regulations and EU restrictive measures
• General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) and ePrivacy
• obligations as they affect partner data handling*International standards*
• FATF Recommendations and FATF guidance for the relevant sector
• Card scheme rules (Visa Core Rules, Mastercard Rules) insofar as they affect merchant
• and partner onboarding

Skills And Experience Required

• ***Essential***
• 3+ years' experience in KYC, KYB, AML, or financial crime due diligence, with at least
• 12 months in the igaming, payments, fintech or crypto sector
• Demonstrable experience conducting UBO analysis
• Strong working knowledge of the ADGM, UK and EU regulatory frameworks listed
• above
• Hands-on experience with industry-standard screening and onboarding tools
• Experience preparing decision-ready due diligence reports for senior compliance andcommercial stakeholders
• Sound judgment on risk; comfortable making and defending recommendations on
• commercially sensitive matters
• Strong attention to detail and a methodical, evidence-based approach
• ***Desirable***
• Professional qualification (ICA Diploma in AML or KYC/CDD, ACAMS CAMS,
• ACAMS CCAS for crypto, or equivalent)
• Experience with payment partner onboarding from both sides - onboarding PSPs and being onboarded by acquirers/EMIs
• Personal attributes
• Discreet and professional handling of sensitive information
• Curious and tenacious in investigating complex structures and resolving red flags
• Comfortable saying no to commercial pressure when the risk picture warrants it
• Collaborative, with the ability to explain compliance requirements to non-specialist colleagues without becoming a blocker **Continuous-improvement mindset; alert to regulatory developments, sanctions** designations, and emerging financial crime typologies
• Key relationships
• Head of Compliance / MLRO (line manager)
• Legal team and General Counsel
• Commercial, Partnerships and Affiliates teams (primary internal clients)
• Payments and Treasury team
• Finance and Internal Audit
• External partners and counterparties during onboarding
• External screening, verification and analytics vendors
• Pay: AED8,000.00 - AED12,000.00 per month

Application Question(S)

• Have you been educated at a UK, Commonwealth or European university?

Language

• English (Required)

Location

• Dubai (Required)