Location: Vilnius, Lithuania

Work: Hybrid

Type: Full-time

Mission

Pax2pay is a rapidly growing FinTech business on a mission to modernise and simplify payments for the travel industry. Our customers are some of the biggest players in the travel sector, and our partners are key players in the FinTech world. Established in 2019, we are a growing team with the aim of becoming the number one choice for B2B payments within the UK and EEA.

History

Pax2pay has an award-winning digital payment solution, making travel payments easier, faster, and safer for the entire travel industry. We enable businesses to pay for their business costs via virtual cards and bank transfers — everything from hotel bookings to flights, travel transfers to tour bookings, utilities to SaaS subscriptions — whatever it is, we've got you covered. Pax2pay has settled billions of pounds worth of transactions, won numerous industry awards including 'Most Disruptive Payments Technology', and supported some of the largest and most successful players in the travel space.

The Opportunity

This is a rare chance to build a compliance function from the ground up. Pax2pay's Lithuanian entity, UAB Pax2pay, is working towards securing an Electronic Money Institution (EMI) licence from the Bank of Lithuania — and as MLRO, you'll be at the centre of that journey, not joining after the hard part is done. You'll help shape the licence application itself, build the policies and controls it depends on, and hire and grow the team that will run AML/CTF for the business as it scales. It's a genuine opportunity to build something from scratch and grow into a senior leadership role as the Vilnius office expands.

The Role

Pax2pay is looking to hire a full-time Money Laundering Reporting Officer (Pinigų Plovimo Ir Teroristų Finansavimo Prevencijos Atitikties Pareigūnas) for its Vilnius office. Ahead of the EMI licence being granted, the MLRO will work closely with Pax2pay's UK AML and Operations teams, and will lead the build-out of the AML/CTF/sanctions framework that underpins the licence application. Once licensed, the MLRO will take on full responsibility for managing the company's obligations related to the prevention, identification, and reporting of money laundering, terrorism financing, proliferation financing, and sanctions evasion — designing, implementing, evaluating, and championing a culture of AML/CTF compliance throughout the organisation. Alongside this, the MLRO will build and lead the Vilnius compliance team as it grows.

Responsibilities

• Working closely with Pax2pay's UK AML and Operations teams in the run-up to the EMI licence being granted
• Leading the AML/CTF/proliferation financing/sanctions evasion workstream of the Bank of Lithuania EMI licence application, including drafting the policies, procedures, and risk assessments, required for licensing, also later during normal company’s activities
• Building, managing, and growing the Vilnius AML, CTF, sanctions team as the entity scales to 20 people, including hiring and mentoring team members and embedding a strong AML/CTF culture
• Regular review and development of AML/CTF/proliferation financing/sanctions evasion related risk management policies and procedures
• Ensuring that ML/TF/proliferation financing/sanctions evasion prevention measures are adequately covered by the company's internal control system, and that risk control and management procedures are proportionate to the scale and nature of the company's activities
• After license receipt being a key point of contact for the Bank of Lithuania and the Financial Crime Investigation Service (FNTT)
• Ensuring the appropriate delivery of company-wide AML/CTF, CDD/EDD, transaction monitoring, and sanctions screening training and ongoing training
• Ensuring the team are provided with updates and reports on ML/TF/proliferation financing/sanctions evasion typologies on a regular and case-by-case basis (when necessary)
• Escalating identified regulatory and control issues to employees, managers, and board members
• Managing suspicious activity reporting processes, reviewing internal SARs, and preparing and submitting external SARs
• In collaboration with the Compliance Officer, conducting investigations and preparing replies to RFI requests from partner banks and payment service providers
• Performing enterprise-wide ML/TF/proliferation financing/sanctions/fraud risk assessments
• Participating in configuring ML/TF/proliferation financing/sanctions evasion prevention technology solutions
• Participating in the design and configuration of new products or services to ensure ML/TF/proliferation financing/sanctions evasion prevention
• Performing other functions and duties, including but not limited to reporting to relevant regulatory authorities outside of the usual SAR process

Requirements

• ACAMS, ICA, or an equivalent certificate in AML/CTF compliance
• At least 3 years' experience as an MLRO or AML Team Head, or 5+ years' experience across other AML-related roles (e.g. KYC, CDD, EDD, transaction monitoring), preferably in the banking, electronic money, or payment processing sector
• Proven managerial / people leadership experience
• Experience supporting or leading an EMI or payment institution licence application with the Bank of Lithuania is highly desirable
• Fitness and probity for the purposes of carrying out regulated activities
• Legal full-time resident in Lithuania for the purposes of employment
• Working knowledge of Lithuanian AML/CTF/proliferation financing/sanctions evasion law and FNTT reporting requirements
• Experience in customer onboarding
• Fluent in Lithuanian and English
• The ability and finesse to both work with and challenge the Board and senior management when necessary