The posting
Join the Pioneer Crypto Brand in the Philippines!
Coins is the most established crypto brand in The Philippines and has gained the trust of more than 18 million users. Through the easy-to-use mobile app, users can buy and sell a variety of different cryptocurrencies and access a wide range of financial services.
Coins is fully regulated by the Bangko Sentral ng Pilipinas (BSP) and is the first ever crypto-based company in Asia to hold both Virtual Currency and Electronic Money Issuer licenses from a central bank.
This is the first compliance hire for our North American businesses: a Canadian and a US money services business in a regulated payments group. You will hold three roles at both entities: Compliance Officer, Risk Officer, and Money Laundering Reporting Officer (MLRO). The job is to build the programs, then run them.
Both businesses are early. They move money across borders for business clients, with foreign exchange where needed, and their volumes are starting now. You will work with a small team and can bring in outside providers for monitoring and reviews, working under your direction. You will report to David.
As Compliance Officer (both entities)
- Build, then keep current, each entity's written compliance program, with policies approved by a senior officer: client and beneficial-ownership due diligence, enhanced measures for higher-risk clients, record keeping, travel-rule data and training.
- Assess money laundering, terrorist financing and sanctions-evasion risk across clients, products, delivery channels and geographies, and assess new products, payment rails and corridors before launch.
- Set the outside compliance provider's scope, review its work and sign off what it produces.
- Run the written, ongoing training program and its training plan for staff and anyone acting for the entities.
- Keep each entity's registrations current: the money services business registration with FINTRAC and the payment service provider registration with the Bank of Canada in Canada; the FinCEN registration in the US, renewed every two years and re-filed within 180 days of a triggering change.
- Lead regulator examinations and requests for information, and answer due-diligence requests from banks, payout partners and clients.
- Monitor state money transmission licensing requirements for the US entity's activity, and advise the business before it enters a new state or product.
As MLRO (both entities)
- Run transaction monitoring and sanctions screening, and decide every escalated alert.
- Canada: file suspicious transaction reports with FINTRAC as soon as practicable after reasonable grounds to suspect are established, and terrorist property reports; oversee the prescribed reports, including international electronic funds transfers and virtual currency receipts of C$10,000 or more.
- US: file suspicious activity reports with FinCEN for suspicious transactions of US$2,000 or more within 30 days of initial detection, and keep them with their supporting documents for five years; oversee currency transaction reporting and OFAC blocking and reject reporting.
- Act as the contact for law enforcement requests and production orders, and protect the confidentiality of every report.
As Risk Officer (both entities)
- Canada: act as the senior officer who oversees the written risk management and incident response framework under the Retail Payment Activities Regulations, its incident reports and its third-party risk, and any safeguarding-of-funds framework if end-user funds are held.
- Canada: file the annual report to the Bank of Canada by March 31, and give notice of a significant change or new activity at least five business days before it happens.
- Maintain each entity's risk register and risk appetite, covering compliance, operational, third-party and partner risk, and report it to the board.
- Commission the independent reviews: FINTRAC's effectiveness review at least every two years, the Bank of Canada framework review at least every three years, and the US program's independent review; track every finding to closure.
Must have
- At least 7 years in anti-money-laundering and sanctions compliance at money services businesses, payment companies or the payments arm of a bank, including 3 or more as a compliance officer, MLRO or deputy.
- Deep knowledge of Canada's Proceeds of Crime (Money Laundering) and Terrorist Financing Act and FINTRAC's guidance, and working knowledge of the Retail Payment Activities Act.
- Has built a compliance program, not only run one: written its policies, risk assessment and training plan.
- Has decided on and filed suspicious transaction reports, and has run transaction monitoring and sanctions screening.
- Has taken a business through a FINTRAC, bank-partner or audit examination and closed the findings.
- Due diligence on business clients, including clients that pay out for their own customers, and on banks and payout partners.
- A recognised AML certification, such as CAMS, or equivalent experience.
- Writes clearly for boards, regulators and banks, and works alone across time zones.
- Can pass the background checks regulators and banking partners require.
Can be learned here, or nice to have
- The US Bank Secrecy Act, FinCEN reporting and OFAC sanctions. Specialist support is available while you learn the US regime.
- Operational risk and incident response frameworks.
- Cross-border business payments with foreign exchange, or payments funded in stablecoins or other virtual currency, including the travel rule.
- US state money transmission licensing.
- Payout corridors in Asia-Pacific.
- Has managed outsourced compliance providers or set up monitoring and screening tools.
- Has been the officer of more than one entity at once.
