- AML/CFT
- 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.
- Senior Management Reporting: Prepare and submit semiannual MLRO reports to the Board/Senior Management, detailing the efficacy of the AML/CFT program, identifying deficiencies, and recommending clear remediation steps with deadlines.
- Regulatory Adherence: Ensure strict adherence to the Travel Rule requirements for Virtual Asset transfers, implementing technical solutions for information exchange with counterparty institutions.
- Financial Intelligence Unit (FIU)
- Suspicious Reporting (VA Focused): 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 onchain activity patterns and utilizing external analysis for decisionmaking.
- 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).
- 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.
- 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.
- Virtual Asset Due Diligence (VADD): 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.
- Know Your Transaction (KYT)
- Record-Keeping: Ensure all required documentation relating to CDD, onchain investigation logs, transactions, compliance monitoring, and reporting is maintained and readily retrievable for the minimum statutory period (currently five years).
- 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.
- 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.
- 510 years of progressive experience in AML/CFT compliance, financial crime prevention, or risk management, with at least 3 years specifically within the Virtual Asset/Crypto industry.
- Demonstrated experience operating as an MLRO, Head of Compliance, or Deputy MLRO within the UAE or one of its Financial Free Zones (DIFC, ADGM), with experience adhering to VARA or equivalent DLT regulations.
- Essential Technical Skill: Proven proficiency and handson experience using industrystandard blockchain analytics tools (e.g., Chainalysis, Elliptic, TRM, etc.) for onchain investigations and risk scoring.
- Bachelor's degree in Law, Finance, or a related field.
- Mandatory Certification: Possession of a globally recognized certification, such as Certified Anti-Money Laundering Specialist (CAMS) or Certified Cryptocurrency Investigator (CCI) is highly preferred.
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Money Laundering Reporting Officer - United Arab Emirates - OSL
Description
Job DescriptionAbout OSL
As a subsidiary of the publicly listed OSL Group (
HKEX:
863.HK), OSL Digital Securities is Hong Kong's first and most established SFC-licensed and insured digital asset platform. Operating since 2018, the platform provides institutional-grade digital asset services to corporations, financial institutions, professional and retail investors.
As a pioneer in bridging traditional finance and the digital asset economy, OSL Group adheres to its core concept: Open, Secure, and Licensed, empowering the next generation of global financial infrastructure.
Key Responsibilities
I. Governance, Strategy & Risk Management
Program Ownership:
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.
Liaison:
Serve as the designated point of contact for the UAE FIU, mandatory registration and utilization of the goAML platform for all required reporting.
Monitoring:
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.
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