Compliance Manager, MLRO

ABOUT AIRWALLEX Airwallex is the AI-native financial operating system for a real-time, intelligent economy. More than 676,000 businesses, including McLaren Racing, Qantas, SHEIN, and TikTok, use us, directly or through our platform partners, to run their financial operations or build and monetize financial products of their own. We started in Melbourne in 2015 to build the infrastructure global commerce runs on. We're the regulated backbone behind global payments: not by accident, but by design. A decade plus, 85+ licenses, and a financial infrastructure spanning North America, Europe, the Middle East, and Asia-Pacific. We're co-headquartered in San Francisco and Singapore, with more than 2,300 people across 27 offices. We hire builders with founder-level energy, people who move fast with good judgment, dig in with real curiosity, and make calls from first principles rather than waiting to be told what to do. Read our operating principles https://www.airwallex.com/en-us/operating-principles to see it in full.   About the Team The Financial Crime Compliance (FCC) team at Airwallex is a strategically vital function operating under a clear Three Lines of Defense model. As the independent second line, FCC owns the global AML/CTF program, sanctions framework, risk assessment methodology, and governance infrastructure across all global entities. As Airwallex scales into new markets and deepens its engagement with global regulatory bodies, we are building a world-class compliance organization capable of managing complex financial crime risks at scale. This is an environment where you will tackle high-impact challenges, shape global fintech risk strategies, and help establish foundations for long-term growth. The Role Airwallex is establishing a Spanish Branch Office of Airwallex Netherlands B.V. ("Airwallex NL"), its Dutch-licensed e-money institution regulated by De Nederlandsche Bank ("DNB"), to support its go-to-market strategy in Spain and the broader Southern European region. As Manager, Financial Crime Compliance & the Money Laundering Reporting Officer ("MLRO") for the Spanish Branch Office, you will be responsible for supporting the launch and ongoing compliance maintenance of the Branch Office from a financial crime, regulatory and governance perspective. You will ensure that the Spanish Branch Office operates in accordance with applicable Spanish AML/CTF requirements under Ley 10/2010 de Prevención del Blanqueo de Capitales y de la Financiación del Terrorismo ("Ley 10/2010") and its implementing regulation Real Decreto 304/2014 ("RD 304/2014"), SEPBLAC expectations and reporting requirements, applicable EU AML/CTF and sanctions frameworks, and Airwallex NL's global and regional FCC standards. You will act as the designated Representante ante el SEPBLAC and local FCC lead for Airwallex's Spanish Branch Office, serving as a key point of contact for SEPBLAC, Banco de España, law enforcement agencies, and other relevant Spanish and EU authorities. In addition, you will work cross-functionally with Product, Commercial, Operations, Data, and Legal colleagues to ensure our controls effectively prevent, detect, and report financial crime while enabling sustainable growth in the Spanish and Southern European markets. Responsibilities Regulatory Leadership & SEPBLAC Liaison - Serve as the designated MLRO and Representante ante el SEPBLAC for the Airwallex Spanish Branch, fulfilling local AML/CTF obligations under Ley 10/2010 and RD 304/2014, as applicable to a branch of a DNB-supervised institution operating in Spain. - Act as the primary local contact for SEPBLAC and Banco de España in respect of branch-level supervisory matters, regulatory notifications, and any correspondence or inspections relating to the Spanish Branch. - Support the EMEA Regulatory and Compliance team in managing the Spanish branch notification and approval process with the relevant Spanish authorities, and maintain ongoing compliance with any conditions or requirements attached to branch authorisation. Local Compliance Oversight - Maintain ongoing FCC oversight of the Spanish Branch Office, ensuring that local activities remain within the approved branch perimeter and aligned to Airwallex NL's regulatory permissions. - Provide local compliance advice on Spain-based sales, marketing, and account management activity, ensuring that commercial activity is appropriately controlled and consistent with the Spanish Branch Office model. - Ensure that Spanish-specific AML/CTF and sanctions requirements under Ley 10/2010 and RD 304/2014 are appropriately reflected in local policies, procedures, escalation routes, training, governance, and reporting. - Commission or facilitate the periodic external expert review of the branch's AML programme required under Article 28 of RD 304/2014, and oversee remediation of any findings. Suspicious Activity Reporting & SEPBLAC Engagement - Oversee local processes for identifying, escalating, assessing, and, where required, reporting suspicious activity (comunicaciones de operaciones sospechosas) to SEPBLAC via its secure reporting platform, in accordance with Articles 18–19 of Ley 10/2010. - Work closely with the EMEA FCC team to ensure that Spain-related suspicious activity is identified, investigated, escalated, and documented appropriately, in compliance with the tipping-off prohibition under Article 24 of Ley 10/2010. - Provide MLRO review and decision-making input on Spain-related suspicious activity, customer exits, account restrictions, law enforcement requests, and other financial crime risk outcomes where local Spanish input is required. Commercial Enablement & Risk Advisory - Serve as the embedded compliance partner for the Spanish commercial and sales team, providing day-to-day regulatory guidance on customer queries, product use cases, and market-specific risk scenarios relevant to the Spanish and Southern European market. - Advise on Spanish market-specific compliance considerations for complex client engagements, ensuring appropriate escalation to the EMEA FCC and KYC Ops teams where required. - Support the assessment and launch of new products or commercial initiatives targeting the Spanish market, ensuring controls are proportionate and consistent with SEPBLAC expectations and Airwallex NL's risk appetite. Governance & Reporting - Provide regular compliance MI and reporting to Airwallex NL senior management and relevant Group Risk Committees, covering branch-level risk indicators, regulatory developments, and the effectiveness of local controls. - Maintain and update the branch's formal risk assessment under RD 304/2014, ensuring it reflects the current risk profile of the Spanish Branch and is reviewed at least annually. - Fulfil any local reporting obligations to SEPBLAC or Banco de España arising from the branch's regulatory status, in coordination with Airwallex NL's Compliance and Legal teams. Audit & Remediation - Support the response to SEPBLAC and Banco de España branch-level supervisory enquiries, internal audits, and independent AML reviews, coordinating with the Internal Audit function where necessary. - Drive timely identification and remediation of any local compliance deficiencies, maintaining robust evidence of actions taken. Who You Are We’re looking for people who meet the minimum qualifications for this role. The preferred qualifications are great to have, but are not mandatory. Minimum Qualifications - Education: Bachelor's Degree in Law, Finance, Business, or a related field is preferred. - Experience: 5+ years of experience in financial crime compliance with experience as an MLRO or Representante ante el SEPBLAC within a regulated financial institution, payment institution, or fintech operating in Spain or the broader EU/EEA market. - Regulatory Knowledge: Sound knowledge of Spanish AML/CTF obligations under Ley 10/2010 and RD 304/2014, the role of SEPBLAC as Spain's FIU and supervisory authority, the Órgano de Control Interno (OCI) framework, and Banco de España's oversight of payment institutions; familiarity with how EU AML Directives (AMLD4/AMLD5/AMLD6) and the forthcoming EU AML Regulation (EU) 2024/1624 apply in Spain. - Regulatory Exposure: Prior experience interacting with SEPBLAC and/or Banco de España, whether in a direct or supporting capacity (e.g., branch notifications, STR filings, regulatory correspondence, supervisory inspections). - Operational Judgement: Demonstrated ability to manage suspicious activity escalations, STR filings via SEPBLAC's secure reporting platform, and to make sound, timely compliance decisions in a fast-paced commercial environment. - Stakeholder Management: Ability to credibly engage internal stakeholders across compliance, legal, and commercial functions, and to represent Airwallex professionally before Spanish regulatory authorities. - Language: Business-level proficiency in both Spanish and English is required; the ability to conduct regulatory correspondence and draft compliance documentation in Spanish is essential. Preferred Qualifications - Experience supporting a branch office or cross-border operation of a foreign-licensed financial institution or e-money institution in Spain, with an understanding of the DNB/SEPBLAC and DNB/Banco de España supervisory interface. - Experience in payments, fintech, or e-commerce, supporting cross-border products, card issuing/acquiring, or embedded finance use cases in the Spanish and/or EU market - Recognised professional certification in compliance or financial crime (e.g., CAMS, ICA Diploma, or CGSS). - Experience operating within a regional or global FCC function and partnering across multiple jurisdictions and time zones — particularly within the EU/EEA regulatory framework. - Prior exposure to EU and UN sanctions compliance frameworks and their application in a Spanish commercial context. - Familiarity with SEPBLAC's published sectoral guidance documents, typologies, and risk indicators, and their practical application within a payments/fintech business model. - Strong ability to build relationships and influence senior stakeholders across commercial and compliance functions, balancing business enablement with regulatory rigour. APPLICANT SAFETY POLICY: FRAUD AND THIRD-PARTY RECRUITERS To protect you from recruitment scams, please be aware that Airwallex will not ask for bank details, sensitive ID numbers (i.e. passport), or any form of payment during the application or interview process. All official communication will come from an @airwallex.com http://airwallex.com email address. Please apply only through careers.airwallex.com http://careers.airwallex.com or our official LinkedIn page. Airwallex does not accept unsolicited resumes from search firms/recruiters. Airwallex will not pay any fees to search firms/recruiters if a candidate is submitted by a search firm/recruiter unless an agreement has been entered into with respect to specific open position(s). Search firms/recruiters submitting resumes to Airwallex on an unsolicited basis shall be deemed to accept this condition, regardless of any other provision to the contrary. EQUAL OPPORTUNITY Airwallex is proud to be an equal opportunity employer. We value diversity and anyone seeking employment at Airwallex is considered based on merit, qualifications, competence and talent. We don’t regard color, religion, race, national origin, sexual orientation, ancestry, citizenship, sex, marital or family status, disability, gender, or any other legally protected status when making our hiring decisions. If you have a disability or special need that requires accommodation, please let us know.