The Head of MLRO is responsible for leading and overseeing the Group's Anti-Money Laundering (AML), Counter-Terrorist Financing (CTF), and Financial Crime framework across EU jurisdictions. This role ensures full compliance with EU, local regulatory, and telecom-specific AML obligations, acting as the primary point of contact with regulators, Financial Intelligence Units (FIUs), and law enforcement agencies.
The role combines strategic leadership, regulatory accountability, and hands-on oversight of financial crime risk across telecoms products including prepaid services, mobile money, digital wallets, roaming, interconnect, and B2B wholesale.
Key Responsibilities
Regulatory & Governance
- Act as the Group MLRO in accordance with EU AML Directives (AMLD 4/5/6), local transpositions, and applicable telecom regulations.
- Serve as the primary liaison with EU regulators, FIUs, central banks, and law enforcement authorities.
- Ensure timely submission of Suspicious Activity/Transaction Reports (SARs/STRs) across relevant jurisdictions.
- Provide regular AML risk updates and reporting to the Board, Risk Committee, and senior management.
- Maintain oversight of regulatory inspections, audits, and remediation programs.
AML / CTF Framework
- Design, implement, and continuously enhance the Group AML/CTF framework, policies, and procedures.
- Ensure compliance with EU sanctions regimes, PEP screening, customer due diligence (CDD), enhanced due diligence (EDD), and ongoing monitoring.
- Own the Enterprise-Wide AML Risk Assessment (EWRA) and ensure it reflects telecom-specific risk factors.
- Oversee transaction monitoring, fraud typologies, and telecom abuse risks (e.g. SIM misuse, prepaid anonymity, roaming fraud).
Telecoms & Product Risk Oversight
- Assess and mitigate AML and financial crime risks across telecom offerings, including:
- Prepaid and postpaid services
- Mobile payments and e-money (where applicable)
- Wholesale and interconnect services
- MVNO partnerships and reseller networks
- Provide AML input into new product launches, market entry, and partnerships.
- Ensure third-party and agent AML compliance through risk-based due diligence and ongoing monitoring.
Leadership & Team Management
- Lead, mentor, and develop the AML/Financial Crime team across EU markets.
- Set strategic objectives, KPIs, and performance standards.
- Act as a senior advisor to the business on financial crime risk and regulatory developments.
Training & Culture
- Champion a strong compliance and ethical culture across the organisation.
- Develop and deliver AML/CTF training programs for senior management and staff.
- Ensure ongoing awareness of emerging risks, regulatory updates, and enforcement actions.
Key Skills & Experience
Essential
- Proven experience as an MLRO or Deputy MLRO within a telecoms, fintech, payments, or regulated digital services environment.
- Strong working knowledge of EU AML Directives (AMLD), GDPR, sanctions, and telecom-related compliance obligations.
- Experience dealing with EU regulators, FIUs, and supervisory authorities.
- Deep understanding of telecom-specific financial crime risks, including prepaid services and cross-border activity.
- Demonstrated ability to operate at Board and executive level.
- Experience managing multi-jurisdictional AML frameworks.
Desirable
- Experience with mobile money, e-money, or payment services (PSD2 / EMI exposure).
- Knowledge of MVNO and wholesale telecom models.
- Previous involvement in regulatory inspections or remediation programs.
- Professional certifications (e.g. CAMS, ICA Diploma, ACAMS, CFE).
Education & Qualifications
- Bachelor's degree in Law, Finance, Risk, Compliance, or related discipline.
- Relevant AML/Compliance certification strongly preferred.
Key Competencies
- Strategic thinking and sound regulatory judgement
- Strong stakeholder and regulator management
- Excellent written and verbal communication
- High integrity and independence
- Ability to balance commercial objectives with regulatory obligations
Success Measures
- Strong regulatory relationships with no material AML findings
- Effective detection and reporting of suspicious activity
- Robust AML governance across all EU operations
- Positive regulatory and audit outcomes
- Strong compliance culture across the business
