Overview
Location: London, United Kingdom (Hybrid)
Entity: Kredete Payment Services Limited (United Kingdom)
Reports to: Director of Compliance, EMEA (functional); UK Board of KPSL (statutory / SMF17).
About Kredete
At Kredete, We're building the complete operating system for businesses; One platform. Banking, cards, payments, crypto, AI agents, CRM, HRIS, collaboration—everything. Using Stablecoin and modern payment systems, we make it easy and affordable for businesses to move money across borders. Our mission is to provide accessible, secure, and low-cost financial solutions that improve cash flow and support financial growth for individuals and businesses.
We’ve built a product customers love and a business that scales fast. We operate in 4 global offices (New York, Lagos, London and Riga, Latvia), and are backed by world-class investors. Our teams are shipping payment systems built to run faster and we are expanding across new product lines and markets.
At Kredete you’ll join a company in motion—ambitious, profitable, inclusive and product-driven—where impact is visible, decisions are fast, and growth is real. We believe in customer obsession, continuous learning, and delivering extraordinary outcomes. If you thrive in a fast-paced, team-driven environment where curiosity, trust, and impact matter, you\'ll fit right in.
Regulatory Status & Context
- Regulatory Status: SMF17 under the FCA Senior Managers & Certification Regime upon authorisation; Nominated Officer under POCA 2002 and the Terrorism Act 2000; sanctions accountability consolidated within the SMF17 remit.
- Licence Context: Authorised Electronic Money Institution (EMI) under the Electronic Money Regulations 2011; payment services ancillary under the PSRs 2017.
Role Purpose
The MLRO is the senior individual accountable for the design, build, operation and continuous improvement of Kredete's anti-money laundering, counter-terrorist financing, counter-proliferation financing, sanctions, anti-bribery & corruption and fraud prevention framework, spanning both the pre-FCA authorisation build phase and the post-authorisation operating phase as the Company's SMF17 and Nominated Officer.
Job Requirements
- Regulatory Qualification: Must be eligible and qualified to hold the SMF17 (MLRO) designation under the FCA Senior Managers & Certification Regime (SM&CR).
- Expert Knowledge: Deep, technical understanding of the UK regulatory landscape, specifically POCA 2002, the Terrorism Act 2000, and the Electronic Money Regulations 2011.
- Sector Experience: Proven experience working within an Authorised Electronic Money Institution (EMI) or a high-growth Fintech environment, with a focus on payment services under PSRs 2017.
- Licensing Track Record: Direct experience in leading or supporting the FCA authorisation application process, including drafting Regulatory Business Plans and engaging with FCA case officers.
- Sanctions Expertise: Demonstrated ability to manage sanctions compliance on a consolidated basis, including familiarity with UK OFSI, UN, EU, and US OFAC regimes.
- Operational Leadership: Experience designing and operating CDD, EDD, PEPs, and transaction monitoring systems from the ground up (the "build phase").
- Reporting Authority: Prior experience acting as a Nominated Officer, with a track record of evaluating internal SARs and submitting external reports to the NCA.
- Stakeholder Management: Ability to manage relationships with high-level external bodies (FCA, NCA, OFSI, HMRC) and maintain direct reporting lines to the Board and Chair.
- Integrity & Independence: Strong ethical judgment with the ability to exercise delegated authority independently to decline transactions or pause product launches on financial crime grounds.
Core Responsibilities
- Own the end-to-end financial crime framework for Kredete policies, risk appetite, Business-Wide Risk Assessment, controls, tooling, training and management information ensuring it is proportionate to Kredete’s risk profile.
- Lead the financial crime workstream of the FCA authorisation application pre-licence including the Regulatory Business Plan, Programme of Operations, financial crime questionnaires, Connect submissions, case officer engagement and MLRO interview and post-licence, discharge the SMF17 function in accordance with the Senior Manager Conduct Rules and the individual\'s Statement of Responsibilities.
- Design, implement and operate customer due diligence, enhanced due diligence, PEP and sanctions screening, adverse media screening, ongoing monitoring and transaction monitoring processes, evidencing the rationale for all thresholds, typologies and rules both at pre-licence readiness dry-runs and throughout live operation post-authorisation.
- Act as Nominated Officer: receive and evaluate Internal SARs, submit SARs and DAML/DATF requests to the NCA, manage notice and moratorium periods, maintain a secure SAR register, and enforce tipping-off and confidentiality controls with the full process built, tested and documented pre-licence and operated live post-licence.
- Own sanctions compliance on a consolidated basis within the SMF17 remit, including alignment with UK OFSI, UN, EU and, where relevant, US OFAC regimes, the calibration of screening systems, the investigation and disposition of alerts, the timely reporting of breaches and frozen assets to OFSI, and the handling of licence applications where required.
- Ensure the prompt delivery of Annual Reports to the Board and relevant committee together with the relevant returns and all other financial crime regulatory reporting once authorised.
- Conduct financial crime due diligence on and maintain ongoing oversight of banking partners, safeguarding credit institutions, agents, distributors and technology vendors; review the financial crime clauses of material outsourcing and intra-group service agreements; and ensure compliance with the FCA's outsourcing expectations pre- and post-licence.
- Design and deliver the Company\'s financial crime training curriculum including induction, annual refresher and role-specific training for customer operations, onboarding, senior managers and the Board and contribute to SM&CR implementation, including fit-and-proper assessments, the Management Responsibilities Map and the MLRO's own Statement of Responsibilities.
- Commission and review independent assurance of the framework (internal audit, external reviewers and, where required, skilled person reviewers), own the remediation of findings, and serve as the primary relationship owner with the FCA, NCA, OFSI and HMRC on financial crime matters including s165 information requests, production orders and thematic reviews.
- Exercise delegated authority, within approved thresholds, to decline or exit customers, block or hold transactions, and recommend pausing product launches on financial crime grounds, with material decisions escalated appropriately. Where thresholds are exceeded or statutory duties required, the MLRO acts independently and reports thereafter. The MLRO maintains direct access to the Chair, Board, Director of Compliance EMEA, Group Chief Compliance Officer, internal audit, whistleblowing channels and the Financial Conduct Authority, and supports the resourcing and development of the financial crime team.
Opportunity: At Kredete, we are proud to be an equal opportunity employer. We value diversity and all applicants seeking employment with us are strictly based on merit, competency and qualifications. We do not discriminate based on religion, race, national origin, sexual orientation, sex, marital or family status, disability or gender.
Data Protection: By applying to this role, you consent to the collection and processing of your personal data by Kredete for the purposes of assessing your suitability for the advertised position. All personal data will be processed in accordance with applicable data protection laws.
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