Background

Equity Bank Limited (The "Bank") is incorporated, registered under the Kenyan Companies Act Cap 486 and domiciled in Kenya. The address of the Bank’s registered office is 9th Floor, Equity Centre, P.O. Box 75104 - 00200 Nairobi. The Bank is licensed under the Kenya Banking Act (Chapter 488), and continues to offer retail banking, microfinance and relat...

Job Purpose

The Senior AML Manager – Transaction Monitoring is responsible for strengthening the effectiveness of the Bank’s risk-based Anti-Money Laundering, Counter Financing of Terrorism and Counter Proliferation Financing (AML/CFT/CPF) transaction monitoring framework, detection capabilities and alert oversight across all customer segments, products and channels.

The role provides Second Line governance over monitoring coverage, scenario design and calibration, alert quality and data integrity, supports escalation of suspicious activity to the MLRO, and protects the confidentiality and independence of suspicious transaction reporting.

Key Responsibilities

• Lead risk-based AML/CFT/CPF transaction monitoring governance and coverage across retail, corporate, cash, payments, mobile, agency, trade and cross-border channels.
• Oversee the inventory, design, calibration, validation and effectiveness of detection scenarios, thresholds and customer segmentation.
• Assess missed detections, false positives and detection gaps, and drive improvements.
• Oversee standards for alert prioritisation, investigation quality, ageing, backlogs and escalation.
• Support complex case reviews and timely escalation of suspicious activity to the MLRO.
• Oversee data completeness, system interfaces, migrations, UAT, parallel runs and post-go-live effectiveness of monitoring solutions.
• Report monitoring coverage, alert KPIs, material deficiencies and remediation to Management and Board forums.
• Lead, develop and allocate resources across the Transaction Monitoring team.

Key Accountabilities

• Maintain a documented transaction monitoring framework aligned to POCAMLA, CBK Prudential Guidelines, FATF Standards and the Bank’s AML/CFT/CPF risk assessment.
• Ensure monitoring coverage is mapped to products, channels, customer segments and geographies, and that coverage gaps are identified and remediated.
• Oversee the scenario inventory and the end-to-end scenario lifecycle, including design, approval, below-the-line testing, tuning and periodic validation.
• Ensure thresholds and customer segmentation are risk-based, evidence-supported and documented.
• Analyse alert-to-case and case-to-STR conversion, false positive rates and missed detections to drive detection effectiveness.
• Set and monitor standards for alert investigation quality, SLA adherence, ageing and backlog management, and challenge First Line operational weaknesses.
• Support complex investigations and ensure timely internal escalation of suspicious activity to the MLRO.
• Protect the confidentiality of suspicious activity information and the MLRO’s independence in determining STR reportability.
• Oversee data completeness and integrity of source feeds, reconciliations and interface exceptions affecting monitoring.
• Provide Second Line oversight of monitoring system implementations, upgrades, migrations, UAT and parallel runs.
• Incorporate emerging typologies, including mobile money, agency, trade-based and proliferation financing risks, into detection scenarios.
• Prepare MI on monitoring coverage, alert KPIs, scenario changes and remediation for Management, Board Committees and the Board.
• Support regulatory inspections, independent reviews and audits, and drive remediation of monitoring-related findings.
• Lead, mentor and develop the team, including performance management, capability building and succession planning.

Qualifications

Core Competencies and Skills

• Strong knowledge of AML/CFT/CPF laws, regulations, CBK Prudential Guidelines and FATF Standards.
• Expertise in transaction monitoring systems, detection scenarios, threshold tuning and model validation.
• Strong understanding of banking products, payments, mobile and agency channels and financial crime typologies.
• Strong data analysis capability, including understanding of data lineage, source systems and data quality.
• Strong analytical, investigative and risk assessment capabilities.
• Excellent report writing, Board reporting and executive communication skills.
• Strong stakeholder engagement, influencing and constructive challenge capability.
• Demonstrated leadership, people management and team development skills.
• High integrity, independence, discretion and sound judgement.

Experience

• Minimum 10 years’ experience in AML/CFT/CPF, Financial Crime Compliance, Transaction Monitoring, Investigations or Internal Audit within the financial services sector.
• At least 5 years’ experience in a management role.
• Demonstrated experience in transaction monitoring scenario design, tuning, alert management and system implementation.
• Proven experience supporting suspicious activity investigations and regulatory inspections.
• Prior experience in a Tier 1 bank and familiarity with CBK and FRC supervisory expectations will be an added advantage.

Academic and Professional Qualifications

• Bachelor’s degree in Finance, Banking, Commerce, Accounting, Economics, Information Systems, Data Science or a related field.
• Master’s degree in a relevant discipline will be an added advantage.
• Professional certifications such as CAMS, ICA Diploma in AML, CFE, CPA(K), ACCA or equivalent financial crime qualifications.
• Demonstrated commitment to continuous professional development in AML/CFT/CPF and financial crime analytics.

• Lead risk-based AML/CFT/CPF transaction monitoring governance and coverage across retail, corporate, cash, payments, mobile, agency, trade and cross-border channels.
• Oversee the inventory, design, calibration, validation and effectiveness of detection scenarios, thresholds and customer segmentation.
• Assess missed detections, false positives and detection gaps, and drive improvements.
• Oversee standards for alert prioritisation, investigation quality, ageing, backlogs and escalation.
• Support complex case reviews and timely escalation of suspicious activity to the MLRO.
• Oversee data completeness, system interfaces, migrations, UAT, parallel runs and post-go-live effectiveness of monitoring solutions.
• Report monitoring coverage, alert KPIs, material deficiencies and remediation to Management and Board forums.
• Lead, develop and allocate resources across the Transaction Monitoring team.
• Maintain a documented transaction monitoring framework aligned to POCAMLA, CBK Prudential Guidelines, FATF Standards and the Bank’s AML/CFT/CPF risk assessment.
• Ensure monitoring coverage is mapped to products, channels, customer segments and geographies, and that coverage gaps are identified and remediated.
• Oversee the scenario inventory and the end-to-end scenario lifecycle, including design, approval, below-the-line testing, tuning and periodic validation.
• Ensure thresholds and customer segmentation are risk-based, evidence-supported and documented.
• Analyse alert-to-case and case-to-STR conversion, false positive rates and missed detections to drive detection effectiveness.
• Set and monitor standards for alert investigation quality, SLA adherence, ageing and backlog management, and challenge First Line operational weaknesses.
• Support complex investigations and ensure timely internal escalation of suspicious activity to the MLRO.
• Protect the confidentiality of suspicious activity information and the MLRO’s independence in determining STR reportability.
• Oversee data completeness and integrity of source feeds, reconciliations and interface exceptions affecting monitoring.
• Provide Second Line oversight of monitoring system implementations, upgrades, migrations, UAT and parallel runs.
• Incorporate emerging typologies, including mobile money, agency, trade-based and proliferation financing risks, into detection scenarios.
• Prepare MI on monitoring coverage, alert KPIs, scenario changes and remediation for Management, Board Committees and the Board.
• Support regulatory inspections, independent reviews and audits, and drive remediation of monitoring-related findings.
• Lead, mentor and develop the team, including performance management, capability building and succession planning.

• Strong knowledge of AML/CFT/CPF laws, regulations, CBK Prudential Guidelines and FATF Standards.
• Expertise in transaction monitoring systems, detection scenarios, threshold tuning and model validation.
• Strong understanding of banking products, payments, mobile and agency channels and financial crime typologies.
• Strong data analysis capability, including understanding of data lineage, source systems and data quality.
• Strong analytical, investigative and risk assessment capabilities.
• Excellent report writing, Board reporting and executive communication skills.
• Strong stakeholder engagement, influencing and constructive challenge capability.
• Demonstrated leadership, people management and team development skills.
• High integrity, independence, discretion and sound judgement.

• Bachelor’s degree in Finance, Banking, Commerce, Accounting, Economics, Information Systems, Data Science or a related field.
• Master’s degree in a relevant discipline will be an added advantage.
• Professional certifications such as CAMS, ICA Diploma in AML, CFE, CPA(K), ACCA or equivalent financial crime qualifications.
• Demonstrated commitment to continuous professional development in AML/CFT/CPF and financial crime analytics.