The Senior Compliance Manager will lead and oversee the compliance function of ZOOD PAY’s Payment Institution, ensuring that the company operates in accordance with applicable laws, regulations, regulatory directives, licensing requirements, AML/CFT obligations, sanctions requirements, internal policies, and industry best practices.
The role will be responsible for establishing and maintaining a strong compliance framework across ZOOD PAY’s PI activities, including customer onboarding, KYC/KYB, transaction monitoring, AML/CFT controls, sanctions screening, regulatory reporting, compliance risk assessments, investigations, and regulatory examinations.
The Senior Compliance Manager will act as a key point of contact between ZOOD PAY and relevant regulatory authorities and will work closely with senior management, Operations, Product, Technology, Finance, Legal, Risk, Customer Support, and other business functions to ensure that compliance is embedded into day-to-day operations and new product development.
2. Key Responsibilities
A. Compliance Framework & Governance
- Develop, implement, and continuously improve ZOOD PAY PI's overall compliance framework.
- Establish appropriate compliance policies, procedures, controls, and monitoring mechanisms.
- Ensure compliance with all applicable PI licensing conditions and regulatory requirements.
- Maintain a comprehensive compliance obligations and regulatory requirements register.
- Conduct periodic compliance risk assessments and recommend appropriate mitigating controls.
- Provide regular compliance reports and updates to senior management and relevant governance committees.
- Identify emerging regulatory risks and advise management on required actions.
- Promote a strong compliance culture across the organization.
B. AML/CFT & Financial Crime Compliance
- Lead the implementation and ongoing enhancement of the company's AML/CFT framework.
- Establish and maintain risk-based AML/CFT policies and procedures.
- Oversee customer risk classification and ongoing customer due diligence.
- Ensure appropriate Enhanced Due Diligence (EDD) for high-risk customers, merchants, agents, and business relationships.
- Oversee transaction monitoring and identification of unusual or suspicious transactions.
- Review and investigate alerts, unusual activity, and potential financial crime cases.
- Ensure appropriate escalation and reporting of suspicious transactions in accordance with applicable requirements.
- Maintain appropriate records and documentation for AML/CFT investigations.
- Conduct periodic AML/CFT risk assessments covering customers, products, channels, geography, and transaction types.
C. KYC / KYB / Customer Due Diligence
- Establish and maintain effective KYC/KYB requirements for customers, merchants, agents, distributors, and other relevant counterparties.
- Ensure appropriate customer identification and verification processes.
- Oversee beneficial ownership identification and verification for legal entities.
- Define documentation requirements based on customer and business risk.
- Establish procedures for ongoing KYC reviews and periodic refreshes.
- Monitor KYC quality and identify weaknesses, gaps, or fraudulent documentation.
- Work with Operations and Technology teams to improve automated KYC and onboarding controls.
D. Sanctions & Screening
- Oversee sanctions and watchlist screening processes.
- Ensure appropriate screening of customers, merchants, agents, beneficiaries, and relevant counterparties.
- Establish escalation and investigation procedures for potential sanctions matches.
- Ensure appropriate handling and documentation of false positives and confirmed matches.
- Monitor changes to applicable sanctions regimes and ensure relevant controls are updated.
E. Transaction Monitoring & Fraud Risk
- Develop and maintain risk-based transaction monitoring rules and scenarios.
- Work with Technology and Operations teams to ensure transaction monitoring systems are functioning effectively.
- Review transaction patterns, unusual behavior, velocity, frequency, geographic exposure, and other risk indicators.
- Coordinate with Fraud, Risk, Operations, and Technology teams on suspicious activity and financial crime investigations.
- Recommend improvements to transaction limits, controls, alerts, and risk rules where required.
- Ensure appropriate escalation of material compliance and financial crime risks.
F. Regulatory Compliance & Reporting
- Maintain a strong working relationship with relevant regulatory authorities.
- Coordinate regulatory inspections, examinations, information requests, and compliance reviews.
- Prepare and submit regulatory reports within required timelines.
- Ensure accuracy, completeness, and consistency of regulatory submissions.
- Maintain a regulatory reporting calendar and escalation mechanism for missed or delayed submissions.
- Track regulatory findings and ensure timely remediation.
- Monitor regulatory developments and assess their impact on ZOOD PAY's business.
G. Compliance Monitoring & Testing
- Develop an annual compliance monitoring and testing plan.
- Conduct periodic reviews of business processes and controls.
- Test compliance with KYC, AML/CFT, sanctions, transaction monitoring, customer protection, and other applicable requirements.
- Identify control deficiencies and recommend corrective actions.
- Track remediation activities through to closure.
- Maintain appropriate evidence and documentation for compliance testing.
H. Policies, Procedures & Controls
- Draft, review, and update compliance policies and procedures.
- Ensure policies remain aligned with regulatory requirements and the company's risk profile.
- Establish clear compliance controls across customer onboarding, transactions, agent/merchant management, payments, complaints, and other PI activities.
- Ensure employees understand and follow applicable compliance requirements.
- Maintain proper compliance documentation and records.
I. New Products & Business Activities
- Provide compliance input during the design and launch of new products, services, partnerships, and payment channels.
- Conduct compliance assessments for new products and material changes to existing products.
- Identify regulatory, AML/CFT, sanctions, consumer protection, and operational compliance risks before launch.
- Recommend appropriate controls and approval conditions.
- Participate in Product and Technology governance processes.
J. Training & Compliance Culture
- Develop and deliver compliance and AML/CFT training programs.
- Ensure relevant employees receive appropriate compliance training during onboarding and periodically thereafter.
- Develop specialized training for Operations, Customer Support, Sales, Agents, and other high-risk functions.
- Maintain training records and monitor completion.
- Promote a culture where employees understand their compliance responsibilities and escalation obligations.
K. Internal & External Audit
- Coordinate with Internal Audit, External Audit, regulators, and other assurance functions on compliance-related matters.
- Support regulatory and audit examinations.
- Respond to audit findings and coordinate remediation.
- Ensure compliance evidence and documentation are maintained appropriately.
- Track outstanding compliance issues and report material delays to senior management.
3. Key Deliverables / KPIs
The Senior Compliance Manager – Compliance will be evaluated based on:
- Regulatory compliance status and absence of material regulatory breaches.
- Timely and accurate regulatory reporting.
- Effectiveness of AML/CFT and KYC/KYB controls.
- Effectiveness of transaction monitoring and sanctions screening.
- Timely investigation and escalation of suspicious activities.
- Compliance monitoring and testing completion rate.
- Closure rate and timeliness of audit/regulatory findings.
- KYC/KYB quality and remediation performance.
- Completion of mandatory compliance training.
- Timely implementation of regulatory changes.
- Quality and completeness of compliance documentation.
- Effectiveness of compliance risk identification and mitigation.
- Overall maturity of the PI compliance framework.
