Exepay Ltd
Senior Risk & Compliance Officer
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Role overview
The Senior Risk & Compliance Officer supports the design, implementation, and ongoing enhancement of the firm’s risk management and compliance framework within an FCA-regulated EMI. The role combines strategic leadership with hands-on execution across AML/CFT, safeguarding compliance, enterprise risk management, and FCA regulatory reporting.
The successful candidate will act as a senior support function to the Head of Risk & Compliance, with responsibility for developing policies, calibrating risk methodologies, overseeing financial crime controls, and helping ensure alignment with UK and, ideally, EU regulatory expectations. The role requires a highly analytical individual with a strong understanding of end-to-end payment flows, including onboarding, transaction monitoring, ongoing monitoring, and safeguarding.
Key responsibilities
- Support the development and maintenance of the firm’s risk and compliance framework in line with FCA requirements, including systems and controls expectations under SYSC and financial crime guidance.
- Draft, review, and enhance policies and procedures across AML/CFT, safeguarding, risk management, onboarding, transaction monitoring, and internal controls.
- Lead and maintain the Business-Wide Risk Assessment, ensuring it remains current, risk-based, and proportionate to the firm’s products, customer base, jurisdictions, and delivery channels.
- Design, implement, review, and calibrate customer, client, and merchant risk assessment methodologies, including scoring models, segmentation logic, and periodic review triggers.
- Oversee and challenge financial crime controls across onboarding, KYC/KYB, transaction monitoring, ongoing due diligence, and alert governance.
- Ensure effective integration between onboarding, transaction monitoring, risk assessments, and compliance oversight so that risk indicators are captured and acted upon consistently.
- Support and oversee safeguarding compliance, including safeguarding flows, reconciliations, governance arrangements, and control effectiveness in line with EMR and FCA expectations.
- Own or support FCA reporting and regulatory submissions, including periodic reporting, safeguarding-related reporting where applicable, internal governance reporting, and the preparation of materials for regulatory engagement, audits, and supervisory requests.
- Provide managerial oversight of compliance and/or financial crime personnel, including quality assurance, training, prioritisation, and development of the team.
- Act as an escalation point for complex AML, sanctions, fraud, safeguarding, and broader compliance risk matters, supporting sound decisions and defensible documentation.
- Develop, review, and present management information, risk metrics, thematic analysis, and control effectiveness reporting to senior management and relevant committees.
- Conduct gap analyses, control reviews, and thematic assessments to ensure the compliance framework remains aligned with evolving regulatory and business requirements.
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Skills and experience
- 5+ years of experience in risk and compliance within an EMI, payment institution, acquirer, fintech, or other regulated financial services firm.
- Strong working knowledge of UK AML/CFT requirements, including the risk-based approach and firm-wide risk assessment expectations, with ideally good familiarity with relevant EU AML compliance principles.
- Proven experience drafting policies, procedures, and building compliance and AML frameworks from the ground up.
- Hands-on experience with Business-Wide Risk Assessments, customer or merchant risk assessment methodologies, and calibration of risk scoring frameworks.
- Solid understanding of safeguarding requirements and controls applicable to UK payment institutions and e-money institutions.
- Strong understanding of onboarding, transaction monitoring, ongoing monitoring, and how these controls interact across the customer lifecycle.
- Experience with FCA reporting, regulatory returns, governance MI, and supporting responses to supervisory, audit, or authorisation-related requests.
- Experience managing or mentoring team members within compliance, AML, or risk functions.
- Highly analytical, with the ability to interpret large data sets, identify trends or anomalies, assess control weaknesses, and translate findings into practical remediation.
- Strong written communication skills, including the ability to draft clear policies, framework documents, committee papers, and regulatory-facing materials.
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Desirable Skills & Experience
- Experience in high-risk verticals such as high-risk merchant acquiring, cross-border payments, crypto-adjacent payments, gambling, adult, digital goods, or other sectors with elevated AML/fraud exposure.
- Experience supporting or leading FCA EMI authorisation, change-in-control, variation of permission, or supervisory remediation projects.
- Familiarity with transaction monitoring, fraud, or payment infrastructure tools such as SEON, Fraudio, or Silverflow.
- Exposure to acquiring business models and associated financial crime, fraud, chargeback, and merchant abuse risks.
- Professional certifications such as ICA or ACAMS.
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