Compliance Lead & Deputy MLRO

ABOUT THE ROLE
The successful candidate will lead Compliance Operations and the Compliance Squad, managing the implementation of all mandates assigned to the Compliance function and overseeing the quality, completeness, and timely delivery of all Compliance Squad deliverables. You will coordinate the implementation, maintenance, and continuous improvement of the Compliance and AML/CFT programme. Additionally, you will act as the Deputy MLRO, supporting the MLRO on delegated matters and providing cover during the MLRO’s absence in accordance with formally documented authority and applicable CBUAE appointment and approval requirements.

RESPONSIBILITIES
1. Compliance Operations and Mandate Implementation

• Manage the end-to-end implementation of mandates and projects assigned to Compliance, including regulatory changes, system enhancements, process transformation, supervisory commitments, Group requirements, and approved management or committee actions.
• Translate mandates into practical implementation plans with clear responsibilities, milestones, dependencies, deliverables, and completion criteria.
• Coordinate implementation with relevant business and support functions, ensuring agreed requirements are embedded into policies, procedures, systems, controls, training, and monitoring activities across the organization.
• Maintain a consolidated implementation tracker, validate completion evidence and escalate delays, resource constraints, and unresolved gaps.
• Oversee the transition of completed initiatives into business-as-usual processes, with clearly documented ownership.

2. Compliance Squad Leadership and Delivery

• Lead the Compliance Squad, setting priorities, allocating responsibilities, and overseeing all its deliverables.
• Maintain the Compliance Squad’s delivery roadmap and action backlog, ensuring alignment with approved Compliance priorities and programme commitments.
• Monitor delivery progress, resolve dependencies, and establish appropriate quality-review and approval arrangements.
• Provide direction, coaching, and constructive challenge to Compliance Squad members.
• Coordinate with other squads and functions where their input is required, without assuming management responsibility for those squads or ownership of their deliverables.
• Report Compliance Squad performance, delivery risks, overdue actions, and decisions required to the relevant management and governance forums.

3. Deputy MLRO Support and Absence Cover

• Maintain sufficient knowledge of the AML/CFT framework, material cases, outstanding obligations, and reporting arrangements to provide effective continuity during the MLRO’s absence.
• Support the MLRO on specifically delegated reviews, escalations, investigations, reporting preparation, and regulatory requests.
• During the MLRO’s absence, perform the responsibilities assigned under the documented deputy arrangements, within applicable authority, access rights, and approval requirements.
• Review internal suspicious activity escalations and supporting analysis, and take reporting decisions or submit reports only where authorised under those arrangements.
• Maintain confidentiality and appropriate case records, escalate matters outside delegated authority, and provide a documented handover to the MLRO on their return.
• Preserve the MLRO’s primary ownership and independent decision-making responsibilities when the MLRO is present.

4. AML/CFT Programme, CDD Oversight and Execution

• Manage the implementation and ongoing delivery of the Compliance and AML/CFT programme, working with the MLRO and relevant business and control owners, in line with CBUAE regulations and guidance.
• Ensure completion and quality assurance of Customer Due Diligence (CDD), including onboarding checks, risk classification, and ongoing monitoring.
• Oversee sanctions screening, AML and CTF controls, ensuring effectiveness and regulatory compliance.
• Validate the authenticity of client documentation and ensure records meet regulatory audit standards.
• Review high-risk customer onboarding escalations and refer them to the MLRO for decision, or decide them where authorised under delegated or absence-cover arrangements.
• Coordinate agreed implementation and enhancement activities relating to customer due diligence, enhanced due diligence, sanctions screening, ongoing monitoring, transaction monitoring, internal escalation, and record-keeping.
• Coordinate compliance and financial crime risk-assessment activities and track the implementation of resulting action plans.
• Maintain accurate programme documentation, implementation records, and supporting evidence.

5. Sanctions Compliance Management

• Lead the review, investigation, and disposition of sanctions alerts, ensuring adherence to internal policies and CBUAE expectations.
• Provide independent oversight and challenge of alert handling decisions.
• Establish processes to identify trends, typologies, and emerging risks, and escalate material issues to Senior Management/Board.
• Oversee handling of sanctions referrals, ensuring zero tolerance for breaches and alignment with UAE and international sanctions regimes.

6. Screening & Systems Governance

• Ensure that all screening systems (real-time and batch/overnight) are operational, calibrated, and periodically tested.
• Oversee system effectiveness reviews, tuning, and validation in line with regulatory expectations.
• Ensure proper audit trails and documentation for all screening activities.

7. Compliance Monitoring & Controls

• Design, implement, and continuously improve the Compliance Monitoring Programme (CMP).
• Lead the implementation of internal controls, compliance checks, and assurance testing.
• Ensure adherence to CBUAE Consumer Protection Regulation (CPR), AML Rulebook, and other applicable frameworks.
• Conduct regular compliance reviews and thematic assessments.

8. Regulatory Reporting & Governance

• Oversee preparation and submission of regulatory reports including AML, sanctions, fraud, and compliance attestations (as applicable).
• Ensure timely escalation of material compliance issues, control weaknesses, and missed commitments to Senior Management and, where required, to CBUAE, with clear recommendations and accountable action owners.
• Develop and maintain compliance metrics/KPIs, dashboards, and reporting packs for governance committees.
• Produce monthly and ad hoc management and committee reports covering Compliance Operations, programme implementation, and outstanding commitments, with actionable insights.
• Coordinate responses to internal audit, Group, and external assurance requests within the assigned scope, ensuring accuracy, completeness, and timely delivery through authorised channels.
• Track audit and regulatory findings and remediation actions, challenge inadequate responses, and validate supporting evidence before recommending closure.

9. Advisory & Continuous Improvement

• Act as a trusted advisor to business functions, providing guidance on compliance risks and regulatory requirements.
• Identify gaps, weaknesses, and control deficiencies, including through programme effectiveness indicators, and lead remediation initiatives with accountable owners.
• Drive continuous improvement in line with international best practices and UAE regulatory expectations.

10. Regulatory & Licensing Support

• As part of Compliance Function, lead and support CBUAE licensing and supervisory interactions, including inspections and information requests.
• Ensure compliance with AML/CFT obligations, KYC standards, and Consumer Protection requirements.
• Oversee regulatory disclosures, product approvals, and policy alignment with applicable laws.

11. Consumer Protection & Conduct Compliance

• Ensure alignment with Consumer Protection Regulation (CPR), including fair treatment of customers and transparency requirements.
• Oversee compliance with customer communication, disclosures, and complaint handling standards.

12. Culture, Training & Awareness

• Promote a strong compliance culture across the organization.
• Oversee delivery of AML/CFT and compliance training programs.
• Ensure staff awareness of sanctions, financial crime, and regulatory obligations.

Accountability Boundaries

• Primary responsibility: Compliance Operations, Compliance Squad leadership, and implementation of mandates assigned to Compliance.
• Deputy responsibility: Support on delegated MLRO matters and formal cover during the MLRO’s absence; not unrestricted parallel ownership of the MLRO role.
• Other squads: Coordination only, unless a specific responsibility is expressly assigned.
• First-line activities: Business and control owners retain responsibility for operating their processes and controls. Ownership of KYC processing, screening, or transaction-monitoring operations is not transferred to this role unless expressly included in the approved operating model.

YOUR PROFILE

• At least 8 years’ experience in a compliance role with a focus on sanction screening, or financial crime investigation.
• Compliance risk experience including relevant sanctions experience.
• Proficiency in using sanctions screening software and tools. Comfortable with data analysis and reporting tools.
• Knowledge of sanction regimes and AML principles.
• Exceptional attention to detail and accuracy in conducting screenings and investigations.
• Excellent communication skills with the ability to effectively communicate findings and recommendations to stakeholders at all levels.
• Effective team player with the ability to work collaboratively.
• Proven experience leading a compliance team and managing the delivery of regulatory change, implementation, or remediation programmes.
• Sound working knowledge of suspicious activity escalation, investigation and reporting, sufficient to act as Deputy MLRO.
• Able to meet CBUAE fit and proper requirements for appointment to the Deputy MLRO role.
• Professional qualification (like ACAMS, CGSS) is required.