Position overview

We are looking for a Head of AFC to lead Xapo's first-line financial-crime operation as an accountable function with owned outcomes, not a queue awaiting instruction. Sitting at a Director level just below the MLRO and CRO, you will own the end-to-end operational response to financial-crime risk across both of our regulated entities (Xapo Bank and Xapo VASP).

This role exists so that our second-line compliance leaders can step back to pure assurance, confident that the first line is led by someone who owns the numbers and the judgement. You will operate inside defined, costed appetite bands set by the second line, working closely alongside product, tech, and operational leads to tune out unnecessary onboarding friction without ever trading off control.

Responsibilities

• Own the AFC operating model: Design, scale, and run the end-to-end first-line process for alerts, RFIs, onboarding review, screening, and monitoring across both entities.
• Operate inside appetite: Hold the operation firmly within Board-ratified appetite bands; make definitive judgements inside those bands and escalate strictly by exception.
• Move the metrics: Take total accountability for our AFC metric set—including open-alert volume and ageing, manual-review rates, automated clearance, false-positive and blocked-payment ratios, and iSAR timeliness/quality.
• Balance cost and risk: Partner with the CFO to map the capital and cost-to-serve impact of the operation, ensuring financial-crime effectiveness and cost are managed as one unified balance sheet.
• Represent the first line in Product Groups: Sit on the Growth and Payments Business Unit PGCs as the operational KYC/AML owner, taking direct responsibility for the financial-crime rules that drive friction.
• Lead and clear bottlenecks: Line-manage and continuously develop our AFC analysts, cross-training the team to actively remove single-person dependencies that route decisions upward.
• Optimize user friction: Continuously tune the manual-review model so it stops delaying customer approvals by days or causing onboarding drop-offs over the weekends.
• Build quality into the trendline: Encode lessons from incidents and near-misses directly back into first-line standards so issues do not recur.
• Leverage AI responsibly: Partner with our CISO and AI teams to systematically raise automated clearance rates and cut false positives through a governed model.
• Own the data: Produce the business-essential reporting that doesn't exist today—showing manual-review volumes, cost-to-serve, and remediation against appetite so stakeholders never have to reconstruct our numbers from the outside.

Skills needed

• First-line operational leadership: Substantial experience leading a first-line financial-crime operation inside a regulated bank, fintech, or crypto institution. You must have run the function operationally, not just advised on it.
• Proven metric ownership: A clear track record of actively owning operational financial-crime metrics and demonstrably moving them toward target parameters.
• Risk-based fluency: Deep competence in calibrating controls to actual risk, maintaining an acute ability to avoid the "over-blocking/de-risking" failure mode.
• Commercial and capital literacy: Comfortable talking numbers, cost-to-serve, and capital impact with a CFO, treating financial efficiency as part of the risk balance.
• Executive presence: The professional credibility needed to evidence, explain, and defend our operating model and risk posture directly to a regulator and the Board.
• Dual-entity comfort: The operational agility to work seamlessly across two distinct regulated entities (Bank and VASP) with separate regulatory frameworks.
• High-ownership mindset: A leadership style focused on giving clear feedback, building operational coverage that spans weekend manual-review bottlenecks, and eliminating silos.