Head of Financial Crime

3 months ago


London, United Kingdom PayPal Full time

**At PayPal (NASDAQ**: PYPL), we believe that every person has the right to participate fully in the global economy. Our mission is to democratize financial services to ensure that everyone, regardless of background or economic standing, has access to affordable, convenient, and secure products and services to take control of their financial lives.

**Job Description Summary**: The UK Head of Financial Crime/MLRO will be based in the UK and will be accountable for ensuring all activity, conducted within PPUK, or globally on behalf of PPUK, related to anti-money laundering and the prevention of terrorist funding is compliant with UK expectations or ensure that any non-compliance is addressed or escalated to the Audit, Risk, Compliance & Conduct Committee (ARCC) and/or PPUK Board where required. The PPUK Board and Senior Management will ensure that the UK Head of Financial Crime/MLRO has the necessary authority and status, is fully independent, with access to resources and information sufficient to enable them to carry out their responsibilities. The UK Head of Financial Crime/MLRO will assume the PPUK Money Laundering Reporting Function (SMF 17) and Nominated Officer responsibilities. As a member of PPUK’s second of defence Risk and Compliance teams will report directly into the second line of defence Chief Risk & Compliance Officer (CRCO) with the ability to escalate any Financial Crime (AML, Sanctions and Anti-Bribery and Corruption) to the PPUK ARCC and PPUK Board.

Accountable for effective oversight, control, and management of PPUK policies, procedures and practices relating to UK AML and CTF issues, to include providing guidance, assistance, and challenge on PPUK’s policies, procedures and practices including those executed on behalf of PPUK by global teams and third parties that support PPUK execute its regulatory obligations.

Work closely with colleagues based across the globe and relevant third parties to ensure that PayPal’s Financial Crime related controls are designed and operating as per UK regulatory requirements.

Support and coordinate management focus on the money laundering and CTF risk in individual business areas in PPUK.

Assist management in developing and maintaining an effective AML and CTF compliance culture for PPUK.

Prepare the annual MLRO report in collaboration with the global PayPal business, using findings and lessons learned from 1st,2nd 3-line assurance reviews, internal business changes and external changes to the business environment to develop a UK picture of Financial Crime risks, issues and controls across PayPal that impact PPUK.

In consultation with management and 1st line colleagues from across PayPal create and maintain the money laundering risk-based approach and the risk assessment of PPUKs customers, products, and services.

Establish and maintain appropriate Financial Crime risk-based monitoring processes proportionate to PPUKs operations, scale, nature, and complexity.

Document PPUKs Financial Crime risk-based strategies and the basis for risk assessment and monitoring.

Ensure immediate investigation of all internal SARs received by PayPal’s Global Financial Crime and Consumer Protection (GFCCP) team.

Ensure the submission of a SAR by PayPal’s Global Financial Crime and Consumer Protection (GFCCP) team to the relevant UK law enforcement agency (National Crime Agency) regarding all suspicions that have substance as required pursuant to PPUK.

Monitor and encourage staff compliance with the PPUK AML & CTF policies and monitor operations and development of the policy. Ensuring that any issues of concern are escalated to ARCC.

Provide management information and regular updated to ARCC and the PPUK Board as necessary, including an annual report each year to PPUKs Board and senior management on PPUKs compliance with its obligations.

Function as a primary point of contact for UK regulators, and in any other third-party enquiries on PPUK’s AML and CTF approach.

Ensure that all relevant staff are adequately trained in money AML and CTF prevention, that the standards and scope of the training are appropriate and that appropriate training records are kept.

Remain aware of any relevant sanctions, prohibitions, and notices. Also ensure that GFCCP management and relevant staff ensure the names of any individuals and institutions on the UK sanctions list are screened in a timely manner.

Provide sign-off on behalf of PPUK where required, to include the new product development approval and launch process for UK products; for marketing materials relating to UK products and for other policies; and for other relevant policies, procedures and practices which relate to, or impact on, PPUK.

Accountable as the UK Head of Financial Crime/MLRO & Financial Crime advisor to the PPUK Board and Senior Management.

Assist and guide the CEO and CRCO on SMCR Financial Crime related responsibilities.

Represent the interests of the PPUK, from an AML & CTF perspective, at


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