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About the Role

The Director, AML Compliance, AMLCO serves as WUFSA's formally appointed Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) Compliance Officer, responsible for leading the Australian AML/CTF compliance function, overseeing the AML/CTF Program, and ensuring compliance with legislative and regulatory requirements. This role also supports the identification, assessment, and management of financial crime risks and provides strategic oversight and subject matter expertise across APAC.

Responsibilities

Serve as the nominated AML/CTF Compliance Officer for WUFSA.
Act as primary contact with AUSTRAC regarding AML/CTF matters.
Oversee and coordinate day-to-day compliance with AML/CTF legislation, sanctions obligations, WUFSA AML/CTF Program, and WU global AML/CTF standards.
Oversee the effectiveness of AML/CTF governance, risk management, and compliance controls.
Escalate material AML/CTF risks, breaches and deficiencies to Senior Management and the Governing Body.
Provide periodic AML/CTF reporting to Senior Management and relevant governance forums.
Formally report AML/CTF compliance outcomes and program effectiveness to the Governing Body at least annually.
Maintain eligibility to perform the role throughout tenure.
Meet all competency, authority, and independence, and fit-and-proper requirements established under WUFSA's AML/CTF Program and associated governance framework.
Own and oversee the WUFSA AML/CTF Program.
Maintain AML/CTF policies, procedures, controls and governance documentation.
Ensure AML/CTF frameworks remain aligned with legislative requirements and regulatory expectations.
Oversee implementation of AML/CTF controls across all designated services.
Ensure AML/CTF documentation remains fit for purpose and current.
Coordinate periodic reviews and updates of the AML/CTF Program.
Oversee remediation of compliance deficiencies, audit findings and regulatory issues.
Perform statutory responsibilities of the AML/CTF Compliance Officer.
Ensure compliance with all AML/CTF reporting obligations, including Suspicious Matter Reports (SMRs), Threshold Transaction Reports (TTRs), International Funds Transfer Instructions (IFTIs) and other regulatory reporting requirements.
Oversee suspicious activity investigations, decision-making and escalation processes.
Oversee the effectiveness of Customer Identification Program (CIP), Customer Due Diligence (CDD), Enhanced Due Diligence (EDD) and ongoing customer monitoring controls.
Ensure AML/CTF risk considerations are incorporated into new products, services, systems, delivery channels and material business change initiatives.
Oversee sanctions compliance controls and escalation of potential sanctions-related matters.
Ensure AML/CTF record-keeping obligations are maintained and periodically tested.
Oversee implementation and monitoring of remediation programs arising from audits, compliance reviews, regulatory examinations and issue management activities.
Maintain regulatory documentation, appointment records and compliance evidence.
Support regulatory examinations, inspections, enquiries and information requests.
Maintain awareness of emerging financial crime typologies, regulatory developments, sanctions risks and industry best practices.
Ensure the organisation's AML/CTF obligations are effectively communicated and understood across relevant business areas.
Oversee the effective design and execution of enterprise AML/CTF risk assessments including associated customer, product, channel and geographic risk assessments.
Ensure effective management of financial crime risks including money laundering, terrorism financing, proliferation financing, sanctions, and fraud, based on risk assessment outcomes and controls being implemented to manage the identified risks.
Ensure enhanced due diligence requirements are effectively implemented.
Review and appropriately challenge other business risk assessments as required.
Escalate material financial crime risks to senior management and governance forums.
Prepare periodic AML/CTF compliance reporting for Senior Management, Governing Body and other governance forums.
Provide formal AML/CTF Compliance Officer reporting to the Governing Body at least annually.
Escalate material AML/CTF incidents, compliance breaches, significant control deficiencies, emerging regulatory concerns and material financial crime risks as required.
Present significant compliance issues, regulatory developments, financial crime trends, breaches and emerging risks to governance forums and senior stakeholders.
Oversee responses to internal / external audit, compliance review, independent evaluation and regulatory findings.
Monitor closure of audit, regulatory and review findings and ensure timely remediation of identified issues.
Maintain effective relationships with regulators, governance stakeholders and relevant internal control functions.
Provide strategic advice and independent challenge to support informed decision-making regarding AML/CTF and financial crime risk matters.
Ensure Senior Management and the Governing Body remain informed of the effectiveness of the AML/CTF Program and material financial crime risks.
Oversee AML/CTF compliance monitoring activities.
Ensure AML/CTF training programs remain effective, current and risk based.
Promote and maintain a strong financial crime compliance culture throughout the organisation.
Coordinate independent review and evaluation of the AML/CTF Program at prescribed intervals.
Monitor remediation and closure of findings arising from independent reviews.
Report progress of remediation activities to Senior Management and the Governing Body.
Assess emerging regulatory developments and recommend enhancements to AML/CTF controls and governance arrangements.
Drive continuous improvement initiatives across financial crime compliance frameworks, systems and controls.
Support the development of AML/CTF capability, awareness and expertise across the organisation.
Maintain ongoing eligibility and suitability as the appointed AML/CTF Compliance Officer and MLRO.
Support periodic Fit and Proper assessments and eligibility reviews.
Maintain records evidencing appointment, eligibility and ongoing suitability.
Ensure regulatory notifications relating to appointment, resignation, replacement or eligibility changes are completed within prescribed timeframes.
Escalate any matter affecting continued eligibility, suitability, independence or regulatory standing.
Ensure governance records relating to appointment remain current and available for review.
Provide expert compliance support and guidance to business stakeholders while ensuring customer outcomes are balanced with regulatory obligations and risk management requirements.
Develops, oversees and enhances compliance frameworks, governance structures, policies and risk management programs.
Possesses extensive expertise in AML/CTF compliance, financial crime risk management, sanctions compliance and regulatory governance.
Provides strategic compliance leadership, influences senior stakeholders and drives a culture of accountability, integrity and regulatory compliance.
Applies deep technical expertise and judgement to oversee AML/CTF risk management frameworks and regulatory compliance obligations.
Possesses extensive knowledge of money laundering, terrorism financing, proliferation financing and sanctions risks relevant to financial services and payments industries.
Maintains awareness of emerging financial crime typologies, regulatory developments, industry trends and best practices.
Provides authoritative advice to Senior Management, governance forums and business stakeholders regarding AML/CTF obligations and financial crime risk management.
Exercises independent judgement in complex and high-risk regulatory and compliance matters.
Influences organisational strategy, governance and risk management outcomes through expert knowledge and thought leadership.
Must immediately disclose any matter that may impact suitability including criminal investigations or proceedings, regulatory investigations or actions, disciplinary actions, material conflicts of interest, insolvency-related matters, or any circumstance that could affect integrity, competence, independence or suitability.
Must disclose any actual, potential or perceived conflict of interest which may impair their independence, objectivity or ability to perform AML/CTF Compliance Officer responsibilities.
Must comply with WUFSA conflict management requirements and promptly notify relevant governance bodies of any material conflicts.
Must immediately disclose any matter that could impact ongoing suitability, independence or effectiveness in the role.
Continued appointment is contingent upon maintaining satisfactory Fit and Proper standing.

Requirements

The incumbent must be an Australian resident and satisfy the eligibility requirements for appointment as an AML/CTF Compliance Officer under applicable AML/CTF legislation.
Advanced knowledge of AML/CTF legislation, regulatory requirements and industry guidance.
Strong understanding of money laundering, terrorism financing, proliferation financing and sanctions risks.
Ability to interpret and apply complex regulatory obligations and expectations.
Experience designing, implementing and overseeing AML/CTF compliance frameworks.
Experience engaging with regulators, governance forums, internal audit and external audit.
Capability to exercise independent judgement and risk-based decision-making.
Ability to effectively challenge business decisions where AML/CTF risks or compliance concerns exist.
Capability to oversee AML/CTF governance, compliance monitoring, reporting and risk management activities.
Hold a management-level position or equivalent authority within the organisation.
Possess sufficient standing and influence to drive compliance outcomes across the business.
Have unrestricted access to Senior Management and the Governing Body.
Maintain direct access to the Governing Body and appropriate governance forums for the purpose of escalating AML/CTF matters independently of operational management.
Have authority to independently escalate ML/TF risks, deficiencies, breaches and regulatory concerns.
Have authority to challenge business decisions where AML/CTF risks are not being appropriately addressed.
Have authority to directly engage and communicate with AUSTRAC and other relevant regulators regarding AML/CTF matters where required.
Have unrestricted access to governance committees and the Governing Body to discharge AML/CTF Compliance Officer responsibilities.
Have authority to request information, documentation and resources necessary to effectively discharge AML/CTF obligations.
Be empowered to recommend corrective actions, control enhancements and remediation initiatives to address identified AML/CTF risks and compliance deficiencies.
Operate independently and objectively in the performance of AML/CTF Compliance Officer responsibilities.
Remain free from undue operational influence or conflicts that may impair independent judgement.
Exercise independent judgement regarding AML/CTF risk management and compliance matters.
Escalate AML/CTF concerns without inappropriate influence or restriction.
Maintain sufficient independence to provide objective oversight, challenge and governance across the AML/CTF Program.
Fit and Proper assessments may include criminal history screening, regulatory enforcement and disciplinary history reviews, employment and reference verification, verification of qualifications, certifications and professional memberships, adverse media screening, conflict of interest assessments, financial probity assessments where permitted under applicable laws, and review of competency, performance and regulatory obligations associated with the role.

Skills

AML/CTF Compliance
Financial Crime Compliance
Financial Crime Risk Management
Regulatory Compliance
AML/CTF legislation
Sanctions compliance
Regulatory reporting
Governance
Controls
Audit/remediation frameworks
Risk assessment
Policy development
Compliance monitoring
Pragmatic risk-based decision-making
Executive communication
Board reporting
Stakeholder engagement
Regulatory liaison
Leadership
Influencing capabilities

Location

Sydney, Australia

Work Type

Hybrid

Experience Level

Minimum 10 years' experience in AML/CTF Compliance, Financial Crime Compliance, Financial Crime Risk Management, Regulatory Compliance or related disciplines.
Minimum 5 years' experience in senior AML/CTF compliance leadership in Australia, for example this could be acting as the AMLCO or Deputy AMLCO in a similar sized organisation, a senior leader who runs a sizable financial crime risk function in a large organisation, or demonstrated experience in acting as, or supporting, an AMLCO within a regulated financial institution, payments provider, remittance business or financial services organisation.
Demonstrated experience engaging directly with regulators, boards, audit committees, executive leadership teams and governance forums.
Demonstrated experience designing, implementing and maintaining AML/CTF frameworks, risk assessments and financial crime control environments.
Demonstrated experience in providing leadership on compliance remediation and transformation programs.

Education Level

Bachelor's degree required in Law, Finance, Business, Risk Management, Accounting, Public Policy, or a related discipline.
Advanced degree preferred.
Postgraduate qualifications in Compliance, Risk Management, Financial Crime or Law is highly desirable.
Professional certifications such as ACAMS certification, ICA Diploma or Advanced Certificate, ACFCS Certification, or other recognised AML/CTF; compliance or financial crime certifications will be highly regarded.

Benefits

Short-term incentives
Accident and life insurance
Access to best-in-class development platforms
Life / Accident Coverage
Superannuation Plan
Paid Time Offs
Employee Wellness
Global Recognition and Rewards Programs

About the Company

Western Union values in-person collaboration, problem solving, and ideation whenever possible. We believe this fosters common ways of working and supports how we execute initiatives for our customers.
We are passionate about honoring our employee's identity and fostering a feeling of belonging. Our commitment is to provide an inclusive culture that celebrates the unique backgrounds and perspectives of our global teams while reflecting the communities we serve.

Equal Opportunity

We do not discriminate based on race, color, national origin, religion, political affiliation, sex (including pregnancy), sexual orientation, gender identity, age, disability, marital status, or veteran status.
The company will provide accommodation to applicants, including those with disabilities, during the recruitment process, following applicable laws.