Head of Financial Crime/ MLRO

JOB PURPOSE:

The Head of Financial Crime/ Money Laundering Reporting Officer (MLRO) is the senior independent officer responsible for ensuring the bank has an effective Anti-Money Laundering, Counter Financing of Terrorism and Counter Proliferation Financing (AML/CFT/CPF) framework and complies with all applicable regulatory requirements. The MLRO is the accountable executive responsible for designing, overseeing, and assuring the effectiveness of the bank's AML/CFT/CPF framework, including regulatory compliance, suspicious transaction reporting, financial crime risk management, and Board reporting.

KEY RESPONSIBILITIES: 

• Lead and oversee the AML/CFT/CPF compliance programme.
• Ensure effective customer due diligence (CDD/KYC), sanctions screening, monitoring, and record-keeping processes.
• Review, investigate and escalate suspicious activities and ensure timely filing of Suspicious Transaction Reports (STRs).
• Monitor the institution's exposure to money laundering, terrorist financing and proliferation financing risks.
• Advise Management and the Board on AML/CFT/CPF risks, regulatory developments, and control weaknesses.
• Act as the primary liaison with regulators, the Financial Reporting Centre (FRC), law enforcement agencies, and external stakeholders on AML/CFT matters.
• Drive AML/CFT training and awareness across the institution.
• Ensure deficiencies are identified, reported, and remediated.
• Maintain sufficient independence, authority, resources, and direct access to Senior Management and the Board to discharge responsibilities effectively

CORE ACCOUNTABILITIES AND DELIVERABLES  

• Develop, implement, and continuously enhance the Bank's AML/CFT/CPF framework, policies, standards, and procedures.
• Ensure compliance with POCAMLA, CBK Prudential Guidelines, FATF Standards, sanctions requirements, and all applicable regulatory obligations.
• Conduct and maintain enterprise-wide AML/CFT/CPF risk assessments and ensure implementation of appropriate risk-based controls.
• Oversee Customer Due Diligence (CDD), Enhanced Due Diligence (EDD), KYC, beneficial ownership verification, and customer risk-rating processes.
• Provide oversight of transaction monitoring, sanctions screening, name screening, and financial crime surveillance systems.
• Review, investigate, and determine the reportability of suspicious activities and ensure timely submission of Suspicious Transaction Reports (STRs) to the Financial Reporting Centre.
• Serve as the primary liaison with regulators, law enforcement agencies, correspondent banks, auditors, and other stakeholders on AML/CFT/CPF matters.
• Provide regular AML/CFT/CPF risk, compliance, control effectiveness, and regulatory reporting to Senior Management, Board Committees, and the Board.
• Escalate significant financial crime, sanctions, regulatory, and compliance risks through established governance structures.
• Lead regulatory inspections, compliance reviews, thematic assessments, and remediation of regulatory findings and audit issues.
• Drive AML/CFT/CPF training, awareness, and capability-building initiatives across the three lines of defense.
• Monitor emerging financial crime typologies, regulatory developments, sanctions risks, and industry best practices and ensure their incorporation into the control environment.
• Ensure robust record-keeping, regulatory reporting, and management information systems supporting AML/CFT/CPF compliance.
• Provide independent advisory support to business, operations, technology, and support functions on financial crime risks and regulatory requirements.
• Track and report key risk indicators, compliance metrics, regulatory obligations, and remediation progress.
• Lead, mentor, and develop the Financial Crime Compliance team while ensuring appropriate resourcing, succession planning, and performance management.
• Foster a strong compliance culture and promote accountability for AML/CFT/CPF obligations across the Bank.
• Support strategic initiatives, product reviews, digitization programmes, and business change activities by ensuring financial crime risks are identified, assessed, and appropriately mitigated.
• Maintain independent access to Senior Management and the Board and provide assurance regarding the adequacy and effectiveness of the Bank's AML/CFT/CPF control framework.

Qualifications

EDUCATION AND EXPERIENCE: 

• Bachelor's degree in Law, Finance, Banking, Commerce, Accounting, Economics, Risk Management, or a related field.
• Master's degree in a relevant discipline will be an added advantage.
• Professional certifications such as CAMS, ICA Diploma in AML, CFE, ACAMS, CRCM, CPA, ACCA, CISI, or equivalent financial crime and compliance qualifications.
• Demonstrated commitment to continuous professional development in AML/CFT/CPF, financial crime compliance, and regulatory risk management
• Minimum 12-15 years' experience in AML/CFT/CPF, Compliance, Financial Crime Risk Management, Risk, Regulatory Compliance, or Internal Audit within the financial services sector.
• At least 5 years' experience in a senior management or leadership role.
• Demonstrated experience in AML/CFT investigations, transaction monitoring, sanctions compliance, regulatory inspections, and financial crime risk management.
• Proven experience engaging regulators, law enforcement agencies, external auditors, and senior governance forums.
• Experience in Board reporting, regulatory remediation, and implementation of enterprise-wide compliance programmes.

KEY TECHNICAL SKILLS & LEADERSHIP COMPETENCIES: 

• Strong knowledge of AML/CFT/CPF laws, regulations, prudential guidelines, and international standards.
• Expertise in financial crime risk management, sanctions compliance, customer due diligence, and transaction monitoring.
• Strong understanding of banking products, operations, and emerging financial crime typologies.
• Ability to interpret and apply regulatory requirements in a practical business environment.
• Strong analytical, investigative, and risk assessment capabilities.
• Excellent report writing, Board reporting, and executive communication skills.
• Strong stakeholder engagement, influencing, and regulatory relationship management capability.
• Demonstrated leadership, people management, and team development skills.
• High integrity, independence, sound judgment, and decision-making capability.