INTRODUCTION

Our client, a real-time payment services company established under the National Payment System (NPS) Act, to address the challenge of inter-bank money transfers in the country and beyond, is seeking to onboard a Manager – Compliance.

JOB SUMMARY

The Manager - Compliance is responsible for leading regulatory compliance execution, AML/CFT/CPF operations, transaction surveillance, data protection and privacy governance, KYC/KYB oversight, regulatory horizon-scanning, compliance quality assurance, and related legal and regulatory advisory activities. S/he will work closely with both internal and external stakeholders and partners to there is effective AML/CFT/CPF & transaction surveillance, data protection, privacy & AI compliance, KYC/KYB & due diligence governance. The Manager – Compliance will be responsible for regulatory compliance & horizon scanning while also supporting operationalization and governance of the business Scheme Council. S/he will establish and maintain a compliance QA process across key business operations. The Manager - Compliance will also support legal and regulatory advisory activities relevant to business operations.

DUTIES & RESPONSIBILITIES

AML/CFT/CPF & Transaction Surveillance

• Oversee daily transaction screening and PEP, sanctions, and adverse/negative-news monitoring
• Supervise resolution of Level 2 sanctions and screening alerts
• Review, validate, and track high-priority Suspicious Transaction Reports (STRs) and Suspicious Activity Reports (SARs)
• Ensure applicable STR/SAR filings are appropriately prepared and submitted to the Financial Reporting Centre (FRC) and CBK
• Regularly calibrate and test transaction-monitoring rules to improve detection effectiveness.
• Monitor emerging financial-crime typologies and recommend appropriate control enhancements.

Data Protection, Privacy & AI Compliance

• Conduct Data Protection Impact Assessments (DPIAs) for new products, tools, systems, and processing activities
• Ensure compliance with the Data Protection Act, 2019, and coordinate applicable Office of the Data Protection Commissioner (ODPC) requirements and filings
• Maintain appropriate privacy governance and data-processing controls
• Establish governance controls for AI/ML models, including fairness, transparency, accountability, and explainability
• Provide compliance oversight for automated decision-making and data-driven technologies
• Support privacy-by-design principles across new products and systems.

KYC/KYB & Due Diligence Governance

• Establish and execute enterprise-wide KYC and KYB onboarding and periodic refresh procedures.
• Ensure participant and merchant onboarding applications are verified and risk-scored within defined turnaround times.
• Maintain scheduled periodic due diligence refresh cycles.
• Ensure high-risk relationships receive appropriate enhanced due diligence.
• Verify Ultimate Beneficial Ownership (UBO), PEP involvement, corporate structures, licenses, and identification documentation.
• Maintain an audit-ready centralized compliance repository.
• Implement automated triggers for expiring licenses, identification documents, and risk-profile updates.

Regulatory Compliance & Horizon Scanning

• Conduct regular regulatory horizon-scanning activities
• Identify legislative and regulatory developments affecting payment operations
• Assess regulatory changes and coordinate implementation of required control or policy changes
• Maintain a centralized repository of regulatory requirements, legal precedents, and relevant compliance opinions.
• Support management with regulatory interpretation and compliance advisory services.

Scheme Governance & Industry Dispute Management

• Support operationalization and governance of the business Scheme Council
• Monitor interbank dispute-resolution SLAs
• Prepare compliance and risk governance packs for Scheme Council meetings
• Conduct quality assurance reviews of interbank clearing and settlement message workflows
• Monitor participant compliance with applicable scheme requirements.

Compliance Quality Assurance

• Establish and maintain compliance QA processes across key operational activities
• Conduct periodic compliance reviews and control testing
• Identify control weaknesses and coordinate remediation
• Maintain evidence and documentation required for internal, external, and regulatory reviews.
• Track compliance issues through to closure.

Legal & Regulatory Governance

• Support legal and regulatory advisory activities relevant to business operations
• Maintain and develop a searchable Digital Legal Opinion Library
• Support interpretation and implementation of applicable regulatory requirements
• Collaborate with Legal, Risk, Operations, Technology, and other functions to resolve compliance matters.

Operational Excellence

• Maintain knowledge of the compliance function and stay abreast with the latest practices, trends, and technologies
• Model best practices in compliance operations and activities in order to ensure maintenance of quality performance
• Update job knowledge by participating in conferences and educational opportunities, reading professional publications, maintaining personal networks, and participating in relevant professional associations
• Maintain quality service and partnerships by establishing and enforcing company compliance policies, procedures, standards, and values
• Put in place proper quality control checks and balances within each operational activity assigned to the function
• Regularly report on key performance indicators (KPIs) for all compliance-led projects and operations, demonstrating progress towards established goals and identifying areas for improvement.
• Any other duties as required.

EDUCATION, SKILLS, KNOWLEDGE & EXPERIENCE REQUIRED

• Bachelor’s Degree in Law, Compliance, Risk Management, Finance, Accounting, Business Administration, Information Systems, or any other relevant and/or related discipline
• Professional qualifications in compliance, AML, risk, privacy, audit, or law is highly desirable
• Relevant certifications such as CAMS, ICA Compliance, CIPP/E, CIPM, CISA, CIA, CPA/ACCA, or equivalent are desirable depending on the area of specialization
• At least 7 years of relevant work experience in compliance, AML/CFT, regulatory affairs, data protection, risk, financial crime, or related functions
• At least 3 years of work experience in a managerial or senior supervisory position
• Experience within banking, payments, FinTech, financial services, or another regulated environment is highly desirable
• Experience with AML transaction monitoring, KYC/KYB, regulatory compliance, and data protection
• Experience dealing with regulators, auditors, law enforcement, or industry scheme stakeholders is an advantage
• AML/CFT/CPF compliance and financial-crime risk management experience
• Sanctions, PEP, adverse media, and transaction screening experience
• Experience with STR/SAR review and regulatory reporting
• Experience conducting KYC/KYB and Enhanced Due Diligence (EDD)
• UBO and corporate-structure analysis skills
• Data protection and privacy compliance as well as DPIA preparation and privacy risk assessment skills
• Regulatory interpretation, horizon-scanning, compliance monitoring, testing, and QA skills
• Experience with AI/ML governance and responsible automated decision-making controls
• Strong understanding of regulatory obligations affecting payment and financial services
• Proficiency with transaction-monitoring, KYC, screening, GRC, case management, and data analysis systems
• Strong investigative and analytical skills
• Excellent report writing and documentation skills
• Strong stakeholder management and communication skills
• Ability to exercise independent compliance judgment and escalate material issues
• Strong attention to detail and ability to manage confidential information
• Ability to work effectively across cross-functional teams (compliance, legal, technology, operations, risk, and business).

• Oversee daily transaction screening and PEP, sanctions, and adverse/negative-news monitoring
• Supervise resolution of Level 2 sanctions and screening alerts
• Review, validate, and track high-priority Suspicious Transaction Reports (STRs) and Suspicious Activity Reports (SARs)
• Ensure applicable STR/SAR filings are appropriately prepared and submitted to the Financial Reporting Centre (FRC) and CBK
• Regularly calibrate and test transaction-monitoring rules to improve detection effectiveness.
• Monitor emerging financial-crime typologies and recommend appropriate control enhancements.
• Conduct Data Protection Impact Assessments (DPIAs) for new products, tools, systems, and processing activities
• Ensure compliance with the Data Protection Act, 2019, and coordinate applicable Office of the Data Protection Commissioner (ODPC) requirements and filings
• Maintain appropriate privacy governance and data-processing controls
• Establish governance controls for AI/ML models, including fairness, transparency, accountability, and explainability
• Provide compliance oversight for automated decision-making and data-driven technologies
• Support privacy-by-design principles across new products and systems.
• Establish and execute enterprise-wide KYC and KYB onboarding and periodic refresh procedures.
• Ensure participant and merchant onboarding applications are verified and risk-scored within defined turnaround times.
• Maintain scheduled periodic due diligence refresh cycles.
• Ensure high-risk relationships receive appropriate enhanced due diligence.
• Verify Ultimate Beneficial Ownership (UBO), PEP involvement, corporate structures, licenses, and identification documentation.
• Maintain an audit-ready centralized compliance repository.
• Implement automated triggers for expiring licenses, identification documents, and risk-profile updates.
• Conduct regular regulatory horizon-scanning activities
• Identify legislative and regulatory developments affecting payment operations
• Assess regulatory changes and coordinate implementation of required control or policy changes
• Maintain a centralized repository of regulatory requirements, legal precedents, and relevant compliance opinions.
• Support management with regulatory interpretation and compliance advisory services.
• Support operationalization and governance of the business Scheme Council
• Monitor interbank dispute-resolution SLAs
• Prepare compliance and risk governance packs for Scheme Council meetings
• Conduct quality assurance reviews of interbank clearing and settlement message workflows
• Monitor participant compliance with applicable scheme requirements.
• Establish and maintain compliance QA processes across key operational activities
• Conduct periodic compliance reviews and control testing
• Identify control weaknesses and coordinate remediation
• Maintain evidence and documentation required for internal, external, and regulatory reviews.
• Track compliance issues through to closure.
• Support legal and regulatory advisory activities relevant to business operations
• Maintain and develop a searchable Digital Legal Opinion Library
• Support interpretation and implementation of applicable regulatory requirements
• Collaborate with Legal, Risk, Operations, Technology, and other functions to resolve compliance matters.
• Maintain knowledge of the compliance function and stay abreast with the latest practices, trends, and technologies
• Model best practices in compliance operations and activities in order to ensure maintenance of quality performance
• Update job knowledge by participating in conferences and educational opportunities, reading professional publications, maintaining personal networks, and participating in relevant professional associations
• Maintain quality service and partnerships by establishing and enforcing company compliance policies, procedures, standards, and values
• Put in place proper quality control checks and balances within each operational activity assigned to the function
• Regularly report on key performance indicators (KPIs) for all compliance-led projects and operations, demonstrating progress towards established goals and identifying areas for improvement.
• Any other duties as required.

• AML/CFT/CPF compliance and financial-crime risk management experience
• Sanctions, PEP, adverse media, and transaction screening experience
• Experience with STR/SAR review and regulatory reporting
• Experience conducting KYC/KYB and Enhanced Due Diligence (EDD)
• UBO and corporate-structure analysis skills
• Data protection and privacy compliance as well as DPIA preparation and privacy risk assessment skills
• Regulatory interpretation, horizon-scanning, compliance monitoring, testing, and QA skills
• Experience with AI/ML governance and responsible automated decision-making controls
• Strong understanding of regulatory obligations affecting payment and financial services
• Proficiency with transaction-monitoring, KYC, screening, GRC, case management, and data analysis systems
• Strong investigative and analytical skills
• Excellent report writing and documentation skills
• Strong stakeholder management and communication skills
• Ability to exercise independent compliance judgment and escalate material issues
• Strong attention to detail and ability to manage confidential information
• Ability to work effectively across cross-functional teams (compliance, legal, technology, operations, risk, and business).

• Bachelor’s Degree in Law, Compliance, Risk Management, Finance, Accounting, Business Administration, Information Systems, or any other relevant and/or related discipline
• Professional qualifications in compliance, AML, risk, privacy, audit, or law is highly desirable
• Relevant certifications such as CAMS, ICA Compliance, CIPP/E, CIPM, CISA, CIA, CPA/ACCA, or equivalent are desirable depending on the area of specialization