Compliance Manager, MLRO

About Airwallex

Airwallex is the only unified payments and financial platform for global businesses. Powered by our unique combination of proprietary infrastructure and software we empower over 250000 businesses worldwide including Brex Rippling Navan Qantas SHEIN and many more with fully integrated solutions to manage everything from business accounts payments spend management and treasury to embedded finance at a global scale.

Proudly founded in Melbourne we have a team of over 2300 of the brightest and most innovative people in tech across 27 offices around the globe. Valued at US$11 billion and backed by world-leading investors including T. Rowe Price Visa Mastercard Robinhood Ventures Sequoia Salesforce Ventures DST Global and Lone Pine Capital Airwallex is leading the charge in building the global payments and financial platform of the future. If youre ready to do the most ambitious work of your career join us.

Attributes We Value

We hire successful builders with founder-like energy who want real impact accelerated learning and true ownership. You bring strong role-related expertise and sharp thinking and youre motivated by our mission and operating principles. You move fast with good judgment dig deep with curiosity and make decisions from first principles balancing speed and rigor.

Youre humble and collaborative; turn zerotoone ideas into real products and you get stuff done end-to-end. You use AI to work smarter and solve problems faster. Here youll tackle complex highvisibility problems with exceptional teammates and grow your career as we build the future of global banking. If that sounds like you lets build whats next.

About the Team

The Financial Crime Compliance (FCC) team at Airwallex is a strategically vital function operating under a clear Three Lines of Defense model. As the independent second line FCC owns the global AML/CTF program sanctions framework risk assessment methodology and governance infrastructure across all global entities. As Airwallex scales into new markets and deepens its engagement with global regulatory bodies we are building a world-class compliance organization capable of managing complex financial crime risks at scale. This is an environment where you will tackle high-impact challenges shape global fintech risk strategies and help establish foundations for long-term growth.

The Role

Airwallex is establishing a Spanish Branch Office of Airwallex Netherlands B.V. (Airwallex NL) its Dutch-licensed e-money institution regulated by De Nederlandsche Bank (DNB) to support its go-to-market strategy in Spain and the broader Southern European region.

As Manager Financial Crime Compliance & the Money Laundering Reporting Officer (MLRO) for the Spanish Branch Office you will be responsible for supporting the launch and ongoing compliance maintenance of the Branch Office from a financial crime regulatory and governance perspective. You will ensure that the Spanish Branch Office operates in accordance with applicable Spanish AML/CTF requirements under Ley 10/2010 de Prevención del Blanqueo de Capitales y de la Financiación del Terrorismo (Ley 10/2010) and its implementing regulation Real Decreto 304/2014 (RD 304/2014) SEPBLAC expectations and reporting requirements applicable EU AML/CTF and sanctions frameworks and Airwallex NLs global and regional FCC standards.

You will act as the designated Representante ante el SEPBLAC and local FCC lead for Airwallexs Spanish Branch Office serving as a key point of contact for SEPBLAC Banco de España law enforcement agencies and other relevant Spanish and EU authorities.

In addition you will work cross-functionally with Product Commercial Operations Data and Legal colleagues to ensure our controls effectively prevent detect and report financial crime while enabling sustainable growth in the Spanish and Southern European markets.

Responsibilities

Regulatory Leadership & SEPBLAC Liaison

• Serve as the designated MLRO and Representante ante el SEPBLAC for the Airwallex Spanish Branch fulfilling local AML/CTF obligations under Ley 10/2010 and RD 304/2014 as applicable to a branch of a DNB-supervised institution operating in Spain.

• Act as the primary local contact for SEPBLAC and Banco de España in respect of branch-level supervisory matters regulatory notifications and any correspondence or inspections relating to the Spanish Branch.

• Support the EMEA Regulatory and Compliance team in managing the Spanish branch notification and approval process with the relevant Spanish authorities and maintain ongoing compliance with any conditions or requirements attached to branch authorisation.

Local Compliance Oversight

• Maintain ongoing FCC oversight of the Spanish Branch Office ensuring that local activities remain within the approved branch perimeter and aligned to Airwallex NLs regulatory permissions.

• Provide local compliance advice on Spain-based sales marketing and account management activity ensuring that commercial activity is appropriately controlled and consistent with the Spanish Branch Office model.

• Ensure that Spanish-specific AML/CTF and sanctions requirements under Ley 10/2010 and RD 304/2014 are appropriately reflected in local policies procedures escalation routes training governance and reporting.

• Commission or facilitate the periodic external expert review of the branchs AML programme required under Article 28 of RD 304/2014 and oversee remediation of any findings.

Suspicious Activity Reporting & SEPBLAC Engagement

• Oversee local processes for identifying escalating assessing and where required reporting suspicious activity (comunicaciones de operaciones sospechosas) to SEPBLAC via its secure reporting platform in accordance with Articles 1819 of Ley 10/2010.

• Work closely with the EMEA FCC team to ensure that Spain-related suspicious activity is identified investigated escalated and documented appropriately in compliance with the tipping-off prohibition under Article 24 of Ley 10/2010.

• Provide MLRO review and decision-making input on Spain-related suspicious activity customer exits account restrictions law enforcement requests and other financial crime risk outcomes where local Spanish input is required.

Commercial Enablement & Risk Advisory

• Serve as the embedded compliance partner for the Spanish commercial and sales team providing day-to-day regulatory guidance on customer queries product use cases and market-specific risk scenarios relevant to the Spanish and Southern European market.

• Advise on Spanish market-specific compliance considerations for complex client engagements ensuring appropriate escalation to the EMEA FCC and KYC Ops teams where required.

• Support the assessment and launch of new products or commercial initiatives targeting the Spanish market ensuring controls are proportionate and consistent with SEPBLAC expectations and Airwallex NLs risk appetite.

Governance & Reporting

• Provide regular compliance MI and reporting to Airwallex NL senior management and relevant Group Risk Committees covering branch-level risk indicators regulatory developments and the effectiveness of local controls.

• Maintain and update the branchs formal risk assessment under RD 304/2014 ensuring it reflects the current risk profile of the Spanish Branch and is reviewed at least annually.

• Fulfil any local reporting obligations to SEPBLAC or Banco de España arising from the branchs regulatory status in coordination with Airwallex NLs Compliance and Legal teams.

Audit & Remediation

• Support the response to SEPBLAC and Banco de España branch-level supervisory enquiries internal audits and independent AML reviews coordinating with the Internal Audit function where necessary.

• Drive timely identification and remediation of any local compliance deficiencies maintaining robust evidence of actions taken.

Who You Are

Were looking for people who meet the minimum qualifications for this role. The preferred qualifications are great to have but are not mandatory.

Minimum Qualifications

• Education: Bachelors Degree in Law Finance Business or a related field is preferred.

• Experience: 5 years of experience in financial crime compliance with experience as an MLRO or Representante ante el SEPBLAC within a regulated financial institution payment institution or fintech operating in Spain or the broader EU/EEA market.

• Regulatory Knowledge: Sound knowledge of Spanish AML/CTF obligations under Ley 10/2010 and RD 304/2014 the role of SEPBLAC as Spains FIU and supervisory authority the Órgano de Control Interno (OCI) framework and Banco de Españas oversight of payment institutions; familiarity with how EU AML Directives (AMLD4/AMLD5/AMLD6) and the forthcoming EU AML Regulation (EU) 2024/1624 apply in Spain.

• Regulatory Exposure: Prior experience interacting with SEPBLAC and/or Banco de España whether in a direct or supporting capacity (e.g. branch notifications STR filings regulatory correspondence supervisory inspections).

• Operational Judgement: Demonstrated ability to manage suspicious activity escalations STR filings via SEPBLACs secure reporting platform and to make sound timely compliance decisions in a fast-paced commercial environment.

• Stakeholder Management: Ability to credibly engage internal stakeholders across compliance legal and commercial functions and to represent Airwallex professionally before Spanish regulatory authorities.

• Language: Business-level proficiency in both Spanish and English is required; the ability to conduct regulatory correspondence and draft compliance documentation in Spanish is essential.

Preferred Qualifications

• Experience supporting a branch office or cross-border operation of a foreign-licensed financial institution or e-money institution in Spain with an understanding of the DNB/SEPBLAC and DNB/Banco de España supervisory interface.

• Experience in payments fintech or e-commerce supporting cross-border products card issuing/acquiring or embedded finance use cases in the Spanish and/or EU market

• Recognised professional certification in compliance or financial crime (e.g. CAMS ICA Diploma or CGSS).

• Experience operating within a regional or global FCC function and partnering across multiple jurisdictions and time zones particularly within the EU/EEA regulatory framework.

• Prior exposure to EU and UN sanctions compliance frameworks and their application in a Spanish commercial context.

• Familiarity with SEPBLACs published sectoral guidance documents typologies and risk indicators and their practical application within a payments/fintech business model.

• Strong ability to build relationships and influence senior stakeholders across commercial and compliance functions balancing business enablement with regulatory rigour.

Applicant Safety Policy: Fraud and Third-Party Recruiters

To protect you from recruitment scams please be aware that Airwallex will not ask for bank details sensitive ID numbers (i.e. passport) or any form of payment during the application or interview process. All official communication will come from an @ email address. Please apply only through or our official LinkedIn page.

Airwallex does not accept unsolicited resumes from search firms/recruiters. Airwallex will not pay any fees to search firms/recruiters if a candidate is submitted by a search firm/recruiter unless an agreement has been entered into with respect to specific open position(s). Search firms/recruiters submitting resumes to Airwallex on an unsolicited basis shall be deemed to accept this condition regardless of any other provision to the contrary.

Equal opportunity

Airwallex is proud to be an equal opportunity employer. We value diversity and anyone seeking employment at Airwallex is considered based on merit qualifications competence and talent. We dont regard color religion race national origin sexual orientation ancestry citizenship sex marital or family status disability gender or any other legally protected status when making our hiring decisions. If you have a disability or special need that requires accommodation please let us know.

Required Experience:

Manager