Group AML & CTF Manager

As a Group AML & CTF Manager at Wise, you will help shape Wise’s Anti-Money Laundering (‘AML’) and Counter Terrorist Financing (‘CTF’) strategy and framework at a global level. You will be providing second line of defence oversight of key AML & CTF control areas including Transaction Monitoring, AML/CTF Investigations, Reporting, and Enhanced Due Diligence (EDD).

This role sits within Wise’s Group Financial Crime Compliance Team, positioned within the Second Line of Defence. This role is pivotal in ensuring Wise’s compliance with global financial crime regulations, as well as ensuring Wise’s AML/ CTF systems and controls are robust and effective in mitigating financial crime risk.

What You'll Be Doing:Governance & Oversight

• Support in the development of Group AML & CTF policies ensuring alignment with international financial crime regulatory requirements (e.g., FATF, UK Bribery Act, US FCPA, etc).
• Scrutinising and challenging the implementation of new controls or changes to existing controls in the AML & CTF framework to ensure design and operating effectiveness.
• Oversight of results from and collaboration with Financial Crime Quality Assurance (‘QA’), Financial Crime Compliance Monitoring and Testing (‘CMT), and Internal Audit (IA).
• Support the Group Financial Crime Governance & Risk Team with the development and monitoring of AML & CTF Management Information (‘MI’), resulting in the publication of trend analysis reports on a global and regional level for senior management.
• Support the Group Financial Crime Governance & Risk Team with oversight on Global AML & CTF issues and incidents, including raising self identified issues, the review and approval of action plans, due dates, and the validation of actions.
• Attendance at relevant AML & CTF related forums and committees to report on progress and key areas of concern as well as add insights. (i.e., quarterly planning sessions, domain level governance etc).

Risk Management

• Work with colleagues in Product and Product Compliance teams to design and implement controls that manage the AML & CTF risks faced by Wise.
• Support in the development and maintenance of risk assessments, coverage assessments, control assessments and gap analysis.
• Ongoing check/challenge/oversight of our Transaction Monitoring controls and EDD controls including supervised and unsupervised machine learning models, static rules and AI solutions.
• Support the Group Financial Crime Governance & Risk Team on the development and maintenance of:
• Country Risk Assessment;
• Industry Risk Assessment;
• Customer Risk Assessment;
• AML & CTF Risk Taxonomies;
• AML & CTF Key Risk Indications (‘KRIs) and Key Performance Indicators (‘KPIs).

Advisory and Support

• You will be responsible for collaborating with a number of Group, and Regional Teams across Compliance, Product Compliance, Product, and FinCrime Operations, this includes:
• Providing AML & CTF subject matter expertise (i.e., remediation activities, responding to general ad-hoc compliance escalations and queries).
• Reviewing and approving new AML & CTF systems and controls, as well as material changes to existing AML & CTF systems and controls, ensuring systems and controls align with global regulatory requirements, as well as effectively mitigating financial crime risk.
• Supporting Product, and Product Compliance on large-scale AML & CTF initiatives requiring cross-functional collaboration.
• Reviewing and approving Product Risk Assessments conducted by Product Risk and Compliance, ensuring the assessment appropriately identifies and mitigates money laundering and terrorist financing risk, as well as aligning with Regional Compliance Teams.
• Supporting Regional Financial Crime Compliance Teams in relation to any AML & CTF tasks, reviews, escalations, and breaches.
• Leading ad-hoc reviews assessing the adequacy and effectiveness of Wise’s AML & CTF systems and controls, identifying enhancement opportunities and providing detailed recommendations.

Knowledge and Awareness

• Review and approval of AML & CTF related procedures and operational guidelines.
• Support the Knowledge Delivery Team and FinCrime Ops developing training needs assessments and skills assessments.
• Support the Knowledge Delivery Team with the delivery and approval of group-wide AML & CTF training material, ensuring the material is adequate, and up-to-date, as well as monitoring training completion.
• Support the Knowledge Delivery Team with the oversight and approval of role-specific AML & CTF tailored training.

What You'll Bring:

• 5+ years experience in financial crime compliance (2LoD experience required), specifically in AML & CTF, with experience at a global financial organisation and/or consultancy.
• Strong understanding of global financial crime regulations, risk management frameworks, and control environments as related to AML/CTF.
• Strong communication skills, with the proven ability to collaborate with a wide-number of people, and the capability to influence cross-function teams and stakeholders.
• Proven ability working independently and taking the lead on a range of AML & CTF initiatives, projects, and reviews.
• Strong analytical skills with the ability to assess AML & CTF risks.
• Relevant degree or certifications (e.g., ACAMS, ICA) are preferred.
• International travel may be required.

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