The posting
1. Role Purpose The Web3 Compliance Officer & MLRO is a foundational hire within PayerMax's Abu Dhabi Compliance team. Reporting to the Web3 Compliance Director, this role is central to (i) obtaining a variation of our existing FSRA Financial Services Permission to include Web3 / virtual-asset-related payment activities, (ii) maintaining the licence and meeting ongoing regulatory obligations, and (iii) acting as a primary point of contact for the FSRA and for external stakeholders such as law firms, audit firms and consultants. The role also carries the statutory Money Laundering Reporting Officer (MLRO) accountability for our ADGM entity. 2. Key Responsibilities 2.1 Licence Variation & Regulatory Authorisations • Lead end-to-end preparation and submission of the FSRA application to vary the entity's Financial Services Permission (FSP) to include Web3 / virtual-asset-related activities, including drafting the narrative, control mapping and supporting documentation. • Coordinate with the Web3 Compliance Director, product, legal and technology teams to evidence the fitness of the proposed business model, systems, controls and resourcing. • Manage regulatory queries and supplementary information requests from the FSRA through to approval, and own post-approval implementation and conditions tracking. • Monitor the evolving ADGM virtual-asset regulatory perimeter (FSRA VA Rules, DLT Foundations regime, guidance) and advise on its application to our licence and roadmap. 2.2 Licence Maintenance & Regulatory Filings • Own the entity's ongoing regulatory reporting and filing calendar (e.g., annual returns, financial-resources reporting, regulatory notifications and event-driven disclosures) and ensure timely, accurate submissions to the FSRA. • Maintain the compliance monitoring programme, risk assessment and management information, and prepare materials for the Board, senior management and the regulator. • Keep the compliance manual, policies and procedures current with ADGM FSRA Conduct of Business, Prudential and AML/CFT requirements. • Act as the entity's liaison for inspections, thematic reviews and ad-hoc information requests. 2.3 Regulatory Engagement & External Stakeholder Management • Serve as a credible day-to-day contact for the FSRA, building and maintaining a constructive, transparent relationship with the supervisory team. • Manage relationships with external law firms, audit firms, compliance consultants and technology vendors engaged on licensing, AML and virtual-asset matters; scope mandates, review deliverables and ensure value for money. • Coordinate internal and external audit activity related to compliance, AML and virtual-asset controls, and drive remediation of findings. • Represent PayerMax in industry and regulator-led consultations where appropriate. 2.4 AML/CFT & MLRO Accountabilities • Act as the entity's Money Laundering Reporting Officer (MLRO), with ultimate responsibility for the AML/CFT framework, suspicious activity reporting (SAR) and escalation to the Financial Intelligence Unit. • Oversee KYC / CDD / EDD, sanctions screening, PEP and adverse-media controls, and the virtual-asset Travel Rule programme. • Maintain the AML/CFT risk assessment, policies and training, and assess the money-laundering and terrorist-financing risk of new Web3 products and corridors. • Ensure the entity meets ADGM FSRA AML Rulebook obligations and FATF standards, and act as the primary AML point of contact for the regulator and the UAE's AML authorities. 2.5 Web3 / Virtual Asset Compliance • Design and operate compliance controls for virtual-asset payment flows, including wallet / VA custody oversight, on-chain monitoring, blockchain analytics and transaction screening. • Advise product and engineering on integrating compliance-by-design into Web3 features (e.g., token support, bridges, staking, stablecoin settlement). • Track global virtual-asset regulatory developments (FATF, Travel Rule, MiCA, regional VA regimes) and assess their relevance to our ADGM licence and cross-border operations. • Support sanctions, market-conduct and consumer-protection compliance specific to virtual assets. 2.6 Governance, Advisory & Training • Provide pragmatic, business-enabling compliance advice across the ADGM entity and to regional stakeholders. • Build and deliver AML, virtual-asset and conduct training; foster a strong compliance culture. • Maintain the approved-persons and fitness-and-probity records and support FSRA approval applications for controlled functions.
1. Key Requirements Mandatory • Bachelor's degree in Law, Finance, Economics or a related discipline (or equivalent practical experience). • 6+ years in financial-services compliance, with demonstrable exposure to payments and/or virtual assets. • Solid working knowledge of AML/CFT frameworks (FATF 40 Recommendations), sanctions, and KYC/CDD. • Experience engaging with a financial regulator and managing licensing or authorisation processes. • Professional AML/CFT certification (e.g., ACAMS, ICA Diploma, or equivalent) or willingness to obtain within 12 months. • Excellent written and verbal communication skills in English, with the ability to produce high-quality regulatory submissions. Highly Desirable / Recommended • Prior recognition as an Approved Person in ADGM (FSRA) or DIFC (DFSA), or eligibility to be approved under the relevant Fit and Proper regime. • Hands-on Web2 payment / fintech experience (cards, payment rails, PSP, remittance, acquiring/issuing), ideally within a regulated payments institution. • Familiarity with ADGM FSRA's Virtual Assets framework, DLT Foundations Regulations, and Conduct / Prudential Rulebooks. • Experience with blockchain analytics and virtual-asset Travel Rule solutions. 2. Competencies & Personal Attributes • Ownership mentality with the ability to operate autonomously in a fast-moving, ambiguous environment. • Strong stakeholder-management and relationship-building skills across regulators, advisors and internal teams. • Commercial, solution-oriented judgement that balances risk and business enablement. • High integrity, discretion and resilience under regulatory scrutiny. • Organised, detail-driven, and able to manage multiple parallel workstreams (licence variation, BAU, audits).



