Team Lead of MLRO

Finom is hiring its first Team Lead of MLROs, who will also be our MLRO and Head of Branch in Portugal. You report to the Head of FinCrime Compliance and wear two hats:

• MLRO and Head of Branch, Portugal: you represent Finom before the Bank of Portugal and other Portuguese authorities, and you build our local AML framework.

• Team Lead of MLROs: you lead the MLROs and Deputy MLROs across our EU branches and shape how they work as one team.

Important

Finom stands against the "Compliance Says No" mentality. We want someone who empowers the business instead of limiting it, challenges the status quo and finds non-standard solutions. You are detail-oriented, critical and analytical, and result-driven.

As a team lead you also grow people: you give clear, honest feedback, build trust with colleagues in different countries, and explain your ideas simply and practically to people outside compliance.

What you should know before joining

This is a build-and-lead role, not a run-the-existing-setup role. Three challenges define it:

1. You start from scratch in Portugal. We have a draft setup, but we need someone to align our group policies with the local Portuguese requirements and to build the rest. That includes setting up regulatory reporting in Portugal. Nobody will hand you a plan, so we expect you to decide what to do and move.

2. You lead peers, not just managers of their own country. Each MLRO is responsible for the same standards in their own country. We want a leader who constantly challenges the status quo and looks for optimization of current processes, not someone who only runs their own country independently.

3. You work across several countries at once. You need strong EU regulatory knowledge and the ability to keep processes homogeneous across countries, while respecting local requirements.

Your responsibilities as MLRO Portugal

• Represent Finom before the Bank of Portugal on AML matters, and before other relevant Portuguese authorities as Head of Branch.

• Set up the Portuguese AML framework: adapt our group policy draft to Portuguese law and put local processes in place.

• Own the CDD and Transaction Monitoring policies and procedures in Portugal.

• Define the SAR reporting requirements in Portugal.

• Define the requirements for reporting to Portuguese authorities on integrity and non-integrity matters, and implement them with the Regulatory Reporting function.

• Bring Portugal-specific insight on financial crime typologies (fraud, money laundering, sanctions evasion) and work with the Risk Management team to turn it into rules, scenarios and controls for Finom's FinCrime Risk Engine.

• Act as the second-line decision-maker on complex, high-risk cases escalated by the first line.

• Contribute to the Enterprise-Wide Risk Assessment cycle and Product Risk Approvals as required.

• Give the first line practical guidance on CDD and TM, maintain procedures and manuals for 2LOD escalations and Risk Management, and run internal AML training.

Your responsibilities as Team Lead

• Lead, coach and develop the MLROs and Deputy MLROs in our EU branches

• Set one standard for how MLROs work: shared playbooks, templates, escalation criteria, SAR decision quality and regulator communication.

• Challenge the team and drive improvements that benefit the whole group, not just one country.

• Be the main contact for Product, Operations, Regulatory Compliance, Regulatory Reporting and other functions on behalf of the MLRO network.

• Own the MLRO-related KRIs and report on them to the Management Board Risk Committee.

• Coordinate regulatory inspections, authority requests and the resulting remediation actions.

Must-haves

• Have the right to work in Portugal, and be a native Portuguese speaker

• At least 4 years in the second line of defence at a regulated payment, e-money or banking institution, including at least 2 years as MLRO or Deputy MLRO for Portugueses Branches

• At least 2 years of people management experience

• Excellent knowledge of Portuguese AML legislation and a thorough understanding of the EU AML, Sanctions and Risk Management framework

• Proven direct experience with regulators, including the Bank of Portugal

• A proactive, start-up mindset: you spot issues, bring in the right stakeholders and drive solutions without waiting to be told

• Nice to have - Experience with data analytics tools, databases and AI tools.