Tamara is Saudi’s first fintech unicorn and is backed by Sanabil Investments, SNB Capital, Checkout.com, amongst others, operating out of its headquarters in Riyadh, Saudi Arabia with other regional and global support offices.
About the role
The Money Laundering Reporting Officer (MLRO) oversees the financial crime compliance framework at Tamara, a finance company licensed and regulated by the Central Bank of the UAE (CBUAE). Reporting directly to the Head of Compliance, UAE, the MLRO operates as a senior and independent second line control function, supporting the identification, assessment, management, monitoring, and reporting of money laundering, terrorist financing, proliferation financing, targeted financial sanctions, and related financial crime risks across the company.
The role assesses internal suspicious activity referrals, submits Suspicious Transaction Reports (STRs) to the UAE Financial Intelligence Unit (FIU) through the approved UAE reporting channels, acts as a key point of contact with the CBUAE and other relevant UAE authorities on financial crime matters, and reports to the Head of Compliance, UAE, Senior Management, and relevant governance forums.
This is a senior position, candidates should have 8 or more years of relevant experience in anti-money laundering (AML), countering the financing of terrorism (CFT), sanctions, or financial crime compliance gained within a regulated financial institution, fintech, finance company, bank, payment service provider, or similar environment, with demonstrated experience engaging with the CBUAE in a comparable financial crime compliance role.
Your responsibilities
Financial crime framework & risk assessments:
- Maintain and oversee the company’s AML, CFT, countering proliferation financing (CPF), targeted financial sanctions, and financial crime compliance framework, ensuring policies, procedures, methodologies, and controls remain aligned with UAE laws, CBUAE requirements, and internal standards.
- Assess the applicability and impact of new or amended UAE AML, CFT, CPF, and sanctions requirements and support the implementation of required changes across the company.
- Lead the company’s institutional money laundering, terrorist financing, and proliferation financing risk assessment, covering risks relating to customers, products, merchants, delivery channels, geographies, technology, outsourcing, and new business activities.
- Ensure risk assessment outcomes are translated into proportionate controls, monitoring activities, and risk-based priorities.
Customer due diligence & sanctions oversight:
- Establish second line requirements for customer identification, verification, due diligence, enhanced due diligence, beneficial ownership, source of funds, and customer risk classification.
- Provide oversight and challenge of first line onboarding and due diligence controls, review material or high-risk cases escalated to the second line, and advise Senior Management before decisions are taken to onboard or retain high-risk customers.
- Maintain oversight of sanctions, politically exposed persons (PEPs), watchlist, and adverse media screening requirements, and review material sanctions escalations and advise on appropriate action.
- Oversee compliance with applicable UAE targeted financial sanctions requirements, including the implementation of funds freezing measures, the handling of search and freeze instructions received from the relevant UAE authorities, and related reporting obligations
Transaction monitoring & suspicious transaction reporting:
- Oversee the effectiveness of the company’s transaction monitoring arrangements, including scenarios, thresholds, alert handling, investigations, and case management, and review material or complex cases escalated by the first line.
- Escalate control weaknesses, backlogs, data issues, or system limitations affecting financial crime controls and monitor remediation through to closure.
- Assess internal suspicious transaction and activity referrals, determine whether external reporting is required, and submit STRs, Suspicious Activity Reports (SARs), and other applicable reports to the UAE FIU through the approved UAE reporting channels.
- Implement appropriate follow-up actions after reporting, maintain strict confidentiality, prevent tipping off, and maintain records supporting decisions to report or not to report.
Regulatory engagement & governance reporting:
- Act as a key point of contact for the CBUAE, the UAE FIU, and other relevant UAE authorities on AML, CFT, CPF, sanctions, and financial crime matters, including requests from law enforcement agencies.
- Coordinate financial crime regulatory reporting, notifications, inspections, information requests, and supervisory reviews, ensuring submissions are accurate, complete, supported, and completed within applicable timelines.
- Prepare and submit the semi-annual MLRO compliance report to Senior Management and the CBUAE in line with applicable UAE requirements.
- Provide regular reporting to the Head of Compliance, UAE, Senior Management, and relevant governance forums on financial crime risks, control effectiveness, suspicious activity, sanctions matters, breaches, regulatory developments, and remediation progress.
- Escalate significant financial crime concerns, control failures, or regulatory matters to the Head of Compliance, UAE, and Senior Management without undue delay.
Compliance monitoring, remediation & new business:
- Develop and oversee risk-based financial crime monitoring activities, including thematic reviews, file testing, and control assessments.
- Ensure identified gaps and remediation actions are documented, assigned, and tracked to closure, and coordinate with Internal Audit while maintaining the distinction between second line oversight and third line assurance.
- Assess financial crime risks arising from new products, services, technologies, partnerships, outsourcing arrangements, and material business changes, and define the required AML, CFT, sanctions, screening, and monitoring controls before implementation.
- Oversee relevant financial crime controls performed by service providers or group entities supporting the company’s UAE operations.
Training, records & team leadership:
- Oversee the company’s AML, CFT, CPF, sanctions, and financial crime training programme, ensuring training is appropriate to employee roles and risk exposure, including Senior Management and the Board.
- Ensure appropriate records, supporting evidence, management information, and regulatory documentation are maintained in line with UAE record-keeping requirements.
- Lead and develop the UAE Financial Crime Compliance team, maintaining clear responsibilities and appropriate segregation of duties within the function
- Ensure the function has sufficient skills, capacity, systems, and resources, and escalate material resource or capacity constraints to the Head of Compliance, UAE.
Your expertise
- 8 or more years of relevant experience in AML, CFT, sanctions, financial crime compliance, or a related control function within a regulated financial institution, fintech, finance company, bank, payment service provider, or similar environment.
- Strong understanding of UAE AML, CFT, CPF, and targeted financial sanctions requirements and CBUAE supervisory expectations.
- Demonstrated experience with suspicious transaction reporting, financial crime investigations, institutional risk assessments, regulatory reporting, and financial crime controls.
- Strong report-writing and documentation skills, including the preparation of MLRO reports, regulatory submissions, and governance reporting.
- Strong stakeholder-management skills, with the ability to work effectively with first line teams, Senior Management, regulators, and group functions.
- Ability to oversee and challenge screening, transaction monitoring, due diligence, and case management controls.
- Ability to lead a team and manage sensitive and confidential information with discretion.