AML & Financial Crime Manager (Portugal Branch)

OUR MISSION IS TO ENABLE EVERYONE TO BUILD WEALTH

We reinvent how trading and investing work by creating exceptional products people love. Fostering a culture of excellence and high velocity is the key to our success. Тoday, we serve over 6 million clients, with more than €38 billion in assets under management — a testament to the scale and trust we’ve built in just a few years.

THE ROLE

The AML & Financial Crime Manager supports the organization in preventing financial crime by providing independent oversight, expertise, and challenge to the First Line of Defense in managing Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF). This role ensures that AML controls, investigations, and reporting processes are implemented effectively and in line with the regulatory requirements, internal policies, and the organization’s risk appetite. The AML & Financial Crime Manager performs advanced reviews, leads Quality Assurance activities, supports suspicious activity reporting decisions, and contributes to strengthening T212’s financial crime control framework. In the context of the Portuguese Branch of Trading 212 EU GmbH, the role also acts as the designated person responsible for normative compliance (Responsável pelo Cumprimento Normativo) under Article 16 of Lei n.º 83/2017 (Portuguese AML Act) and is the primary local owner of the Branch’s internal policies and procedures manual required by Regulamento da CMVM n.º 2/2020.

WHAT YOU’LL DO

- Perform second-line reviews of AML controls, alerts, and investigations conducted by the First Line of Defense to ensure adherence to internal policies, regulatory requirements, and risk standards.

- Conduct Quality Assurance reviews of KYC, Customer Due Diligence and Enhanced Due Diligence files to ensure compliance with internal policies and regulatory requirements.

- Assess the quality and consistency of transaction monitoring investigations and case outcomes, identifying deficiencies and areas for improvement.

- Review internal suspicious activity escalations and determine whether internal cases meet the threshold for external regulatory reporting, in line with internal procedures and escalation frameworks.

- Support the drafting, review, and quality assurance of Suspicious Activity Reports and Suspicious Transaction Reports, ensuring narratives are clear, accurate, and meet regulatory expectations.

- Maintain up-to-date knowledge of AML/CMVM/UIF, Lei n.º 83/2017, Regulamento da CMVM n.º 2/2020, laws, regulatory requirements, and best practices to ensure investigations meet compliance standards.

- Prepare monitoring and Quality Assurance reports summarizing findings, trends, and risk areas for AML management.

- Provide guidance and constructive challenge to operational teams to strengthen AML investigations, documentation standards, and escalation practices.

- Submit the mandatory annual AML/CTF compliance report to the CMVM in accordance with Regulamento da CMVM n.º 2/2020.

- Contribute to the continuous improvement of AML policies, procedures, and control frameworks in response to Quality Assurance findings, risk assessment, and regulatory updates.

- Act as the designated person responsible for normative compliance (Responsável pelo Cumprimento Normativo) for the Financial Intelligence Unit (Unidade de Informação Financeira) and the Central Department of Investigation and Criminal Action (DCIAP) under Article 16 of Lei n.º 83/2017; maintain availability during all Branch business hours.

- Design, implement and maintain the Branch’s standalone internal policies and procedures manual in Portuguese, in compliance with Regulamento da CMVM n.º 2/2020; adapt group AML/CTF policies to Portuguese requirements, documenting all divergences where Portuguese law imposes stricter or different obligations.

- Conduct and maintain a documented money laundering and terrorist financing risk assessment for the Branch, incorporating Portuguese National Risk Assessment findings, local market risk factors and client typologies; update upon material business model or regulatory changes.

- Submit Suspicious Transaction Reports to the Financial Intelligence Unit and the Central Department of Investigation and Criminal Action without undue delay once the threshold for suspicion is met; document all escalation decisions — including decisions not to report — for audit purposes and maintain an internal Suspicious Transaction Report log available for supervisory review.

- Provide second-line oversight and quality assurance over all outsourced AML functions; conduct periodic performance reviews; note that outsourcing does not transfer AML accountability.

- Develop and deliver AML/CTF induction training to all new Branch staff BEFORE they are placed in their roles; deliver annual refresher training; maintain training records for a minimum of five years.

- Ensure all AML records (Customer Due Diligence files, identification documents, Suspicious Transaction Report decisions, screening outcomes, policy version history) are complete, accurate and immediately retrievable; maintain client records for 7 years after end of the business relationship per Article 51 of Lei n.º 83/2017.

- Report any assets subject to international financial sanctions to the competent authorities without undue delay.

- Act as primary local liaison for CMVM, Financial Intelligence Unit and DCIAP on AML/CTF supervisory matters, including during on-site inspections; prepare client file samples and policy documentation for regulatory review in coordination with the Head of AML/CTF and MLRO.

WHAT YOU NEED TO HAVE

- Educational background in Finance, Economics, Law, or a related field.

- At least 5 years of experience in AML, Financial Crime compliance, or related functions within an investment firm, capital markets environment, or a regulatory/supervisory authority in Portugal.

- Strong knowledge of Lei n.º 83/2017, Regulamento da CMVM n.º 2/2020, EU AML Directives, financial crime typologies, and investigative standards.

- Strong initiative, analytical thinking, and problem-solving skills.

- Resilient self-confidence and the ability to remain calm under pressure.

- Strong interpersonal and relationship-building skills; able to collaborate across teams and levels.

- Ability to absorb new information quickly and maintain technical competence in AML investigations.

- Excellent written communication skills, particularly for regulatory documentation and reporting.

- Portuguese language: advanced professional proficiency (required — for policy manual authorship, Financial Intelligence Unit communications, client-facing compliance matters and CMVM inspections).

- English language: professional working proficiency (required — for functional reporting to the Firm’s MLRO, group policy review and HQ alignment).

- Experience in an investment firm or capital markets environment (MiFID II / Código dos Valores Mobiliários) is strongly preferred.

WHAT WE OFFER:

- Challenges that will help you grow and realize your potential fast.

- Opportunity to make a significant impact —you will build innovative services used by millions of investors to build wealth.

- Work with smart, spirited, helpful, high-performing colleagues with a common goal.

- An environment where nothing is set in stone.

- Appreciation for your talent and ideas.

- Generous remuneration package

Bring your ambition to Europe’s fastest-growing mobile broker!