Regulatory Compliance & MLRO

OSL are seeking an experienced Regulatory Compliance & MLRO to lead AML/CFT and broader compliance frameworks for our UAE operations.

This role will play a critical part in ensuring regulatory adherence across digital assets, broker-dealer activities, and payment flows, while managing financial crime risks in a fast-evolving environment.

Develop, implement, manage, and continuously update the comprehensive AML/CFT program, policies, and procedures, ensuring specific controls for

Virtual Asset transfers, wallet management, and cross-chain transactions.

2. **Risk Assessment:**

Conduct and periodically refresh the firm’s comprehensive Institutional Risk Assessment (IRA), specifically identifying, measuring, and mitigating Money Laundering (ML) and Terrorist Financing (TF) risks associated with

new virtual asset listings, decentralised protocols, and emerging financial crime typologies.

Prepare and submit semi-annual MLRO reports to the Board/Senior Management, detailing the efficacy of the AML/CFT program, identifying deficiencies, and recommending clear remediation steps with deadlines.

4. **Regulatory Adherence:**

Ensure strict adherence to the

requirements for Virtual Asset transfers, implementing technical solutions for information exchange with counterparty institutions.

Serve as the designated point of contact for the UAE FIU, mandatory registration and utilization of the

goAML platform

for all required reporting.

Receive, review, scrutinize, and analyze all internal Suspicious Transaction Reports (STRs) and Suspicious Activity Reports (SARs) related to Virtual Asset transfers.

This includes analyzing complex on-chain activity patterns and utilizing external analysis for decision-making.

3. **Mandatory Reporting:**

Oversee the timely submission of all mandatory reports via goAML, including STRs/SARs, Fund Freeze Reports (FFR), Partial Name Match Reports (PNMR), and High-Risk Country Reports (HRC).

4. **Regulatory Communication:**

Handle all communication, inquiries, and requests for information from the Supervisory Authority (e.g., VARA, CBUAE, DFSA, FSRA) and law enforcement agencies concerning

digital asset investigations.

5. **Sanctions Compliance:**

Ensure immediate compliance with targeted financial sanctions regimes, conducting

wallet address screening

and executing

freezing without delay

on funds or assets belonging to sanctioned individuals or entities.

Oversee the effective implementation of Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD) processes, specifically addressing the source of funds/wealth in Virtual Assets and the risk profiling of private wallets and counterparties.

Maintain and optimize the KYT system, utilizing blockchain analytics to monitor transaction flows, flag high-risk clusters (e.g., mixers, darknets, illicit addresses), and ensure alert parameters are effective in detecting unusual activity.

3. **Record-Keeping:**

Ensure all required documentation relating to CDD,

on-chain investigation logs

, transactions, compliance monitoring, and reporting is maintained and readily retrievable for the minimum statutory period (currently five years).

4. **Training:**

Design, execute, and document ongoing AML/CFT training that includes specific modules on

Virtual Asset risk indicators, blockchain analysis tools, and VASP regulatory obligations.

1. **Internal Audit:**

Coordinate and facilitate independent internal and external audits of the AML/CFT program, ensuring specific scrutiny of Virtual Asset controls and prompt implementation of corrective actions for all deficiencies.

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