Money Laundering Reporting Officer (MLRO) – VARA Scope

This is on-site position based in our JLT office in Dubai

We are only considering candidates with prior crypto industry experience and direct exposure to working with VARA-related processes or regulations

Core Responsibilities

Transaction Monitoring: Review and disposition alerts via Chainalysis (KYT), including blockchain risk analysis and escalation of suspicious activity.

High-Risk Client Onboarding & KYC: Conduct Enhanced Due Diligence (EDD) and approve/reject high-risk clients. Manage the full KYC/CDD lifecycle, ensuring robust UBO verification and risk assessment at all stages.

Screening: Perform IEMS, EOCN, and global sanctions screening (UN/OFAC/EU), including investigation and escalation of matches.

Suspicious Activity Reporting: File STRs/SARs with the UAE FIU via goAML in a timely manner.

Travel Rule Compliance: Ensure collection, transmission, and monitoring of required transfer data for virtual asset transfers.

AML Program Ownership & Governance

Program Ownership: Take full ownership of the AML/CFT program, ensuring it is fit-for-purpose and evolves with the business model.

Policy Governance: Design, implement, and maintain internal policies, procedures, and controls in strict alignment with VARA's Compliance & Risk Management Rulebook and UAE Federal Laws.

Risk Management: Conduct business-wide ML/TF risk assessments and ongoing monitoring of the firm's risk profile.

Regulatory Interaction & Reporting

VARA Inspections & Audits: Serve as the primary point of contact and lead coordinator for VARA onsite inspections and thematic reviews.

Regulatory Reporting: Manage all regulatory reporting beyond STRs, including the submission of VASP monthly/quarterly reports and other disclosures required by VARA.

Liaison: Act as the official liaison with the UAE FIU and support all formal interactions with regulatory bodies.

Testing & Oversight

Independent Testing: Coordinate and facilitate independent AML audits (internal or external) to validate the effectiveness of the control environment.

Counterparty Due Diligence: Perform comprehensive VASP and counterparty due diligence to mitigate ecosystem risks.

Training & Records: Deliver specialized AML training to all staff and maintain meticulous, audit-ready records.

Reporting Line: Functional reporting into the Head of Compliance, with a direct escalation path to the CEO and Board of Directors.