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About the Role

This role is the single accountable owner of compliance and financial-crime risk arising from the Program Manager channel, acting as the central first-line escalation and recommendation point for issues within this channel. You will own the Program Managers themselves, including onboarding, monitoring, training, registrations, and identifying those who systematically add risk to Ebury's book.

Responsibilities

• Serve as MLRO for Program Manager onboarding and KYD, making final decisions on approval, rejection, or conditional approval.
• Own the KYD framework, including UBO verification, fit & proper assessments, financial soundness, adverse media, regulatory history, sanctions, and conflict-of-interest.
• Adjudicate all escalations from the PM onboarding workflow and own the periodic re-KYD cycle and trigger-based refreshes.
• Maintain the jurisdictional map of registration and notification requirements for each PM and own application preparation, submission, tracking, and renewal.
• Act as the first point of contact for local regulator queries regarding a PM's status as a distributor.
• Own the policy stack, including KYD policy, PM tiering model, annual review template, UAR escalation playbook, financial promotions standard, and kill-switch and orphan-client protocols.
• Evolve the framework in response to industry change and lessons learned.
• Own the PM-level dashboard aggregating compliance events and benchmarked against peers to identify systemic outliers and trigger reviews, restrictions, retraining, or termination.
• Serve as the central escalation point for compliance and financial-crime issues surfaced through the PM channel, investigating and routing recommendations to local MLROs.
• Maintain a written record of escalations, recommendations, and outcomes, feeding patterns back into the PM-level dashboard and framework.
• Design and run tiered ongoing monitoring programs (high-tier quarterly, medium semi-annual, low annual).
• Own the annual PM review cycle, including fit & proper refresh, financial position, and controls adequacy.
• Report monitoring outcomes to the Partnership Oversight Committee and ExCo.
• Design and maintain the mandatory PM training curriculum, including AML, sanctions, market abuse, financial promotions, and Ebury product and process.
• Own certification standards, completion tracking, and the suspension protocol for lapsed PMs.
• Own PM lifecycle processes, including onboarding sign-off, mid-term reviews, exit and kill-switch playbook, and orphan-client handover protocols.
• Chair the Partnership Oversight Committee and act as the primary point of contact for the PM program in supervisory dialogue.
• Report to the Board and ExCo on partner risk.

Requirements

• 5+ years in financial-services compliance, with at least 5 years in a senior role at an EMI, payment institution, investment firm, or bank with a comparable outsourced-distribution, agent, or program-manager model.
• Demonstrable experience as a named MLRO or deputy MLRO, ideally with onboarding decision-making authority.
• Direct experience overseeing an introducer, agent, or program-manager network at scale, including annual reviews, fit & proper assessments, and supervisory engagement.
• Experience designing and submitting registration or notification filings across multiple jurisdictions (UK and/or EU).
• Track record using data and MI to drive risk-based oversight at scale.
• Strong working knowledge of financial-crime frameworks, outsourcing standards, and conduct expectations across the firm's operating jurisdictions.
• Senior judgment under pressure, comfortable making MLRO decisions that constrain commercial growth when evidence requires it.
• Strong framework-thinker who can scope cleanly.
• Numerate and data-fluent.
• Ability to influence without authority.
• Credible voice in senior stakeholder and supervisory dialogue.

Skills

• Compliance
• Financial Crime Risk
• MLRO
• KYD
• Program Manager Onboarding
• Risk Management
• Data Analysis
• Framework Design
• Stakeholder Engagement
• Regulatory Compliance

Location

• London, UK

Work Type

• Hybrid

Experience Level

• Senior

Salary/Compensations

• Competitive Starting Salary with an annual discretionary bonus

Benefits

• Dedicated Mentorship
• Cutting-Edge Technology
• Clear, Accelerated Career Progression
• Dynamic & Supportive Culture
• Generous Benefits Package (including health care and social benefits)

About the Company

• Ebury helps ambitious businesses unlock global growth.
• Ebury distributes its FX, payments, and risk-management products through ~230 Program Managers.
• Ebury delivers sophisticated, integrated solutions — business accounts, hedging, and financing — on a single platform with a seamless workflow.
• Since its founding in 2009, Ebury has always been a fast-growing leader in fintech.
• Ebury brings together 1,800+ Eburians across nearly 70 cities.
• Ebury has a proprietary platform, purpose-built to help businesses seamlessly streamline and manage global cash flow.
• Ebury focuses on continuous product evolution and innovation to build the infrastructure for borderless growth.

Equal Opportunity

• We believe in inclusion. We stand against discrimination in all forms and are against the intolerance of differences that makes us a modern and successful organisation. At Ebury, you can be whoever you want to be and still feel a sense of belonging no matter your story.