Role Overview
ADDX is seeking an experienced AML/CFT professional to own the anti-money laundering and counter-financing of terrorism programme of ADDX Pte. Ltd. and to serve as its MLRO.
ADDX is regulated by the Monetary Authority of Singapore as a Recognised Market Operator and a holder of a Capital Markets Services licence. The AML/CFT framework is therefore governed by MAS Notice SFA02-N05 and MAS Notice SFA04-N02, together with the corresponding MAS Guidelines.
The role reports to the Head, Group Legal & Compliance. It carries two mandates. The first is ownership of the AML/CFT programme and the MLRO function. The second is delivery of the compliance monitoring and testing programme of ADDX Pte. Ltd. outside AML/CFT, building a second area of depth within the compliance team.
The successful candidate must be able to exercise independent judgement, escalate without prompting, and engage MAS, law enforcement and partner financial institutions directly.
Responsibilities:
1. AML/CFT programme ownership and MLRO function
- Act as MLRO for ADDX Pte. Ltd. and serve as the single reference point to whom employees, officers and representatives must refer suspicious activity.
- Own the AML/CFT policies, procedures and controls, and maintain them against MAS Notice SFA02-N05, MAS Notice SFA04-N02 and the corresponding MAS Guidelines.
- Conduct and maintain the enterprise-wide risk assessment for money laundering, terrorism financing and proliferation financing risks.
- Report on AML/CFT risk, control performance and material escalations to the Head, Group Legal & Compliance and, where required, to senior management and the Board.
- Maintain direct escalation access to senior management and the Board on AML/CFT matters.
2. Customer risk, due diligence and transaction monitoring
- Act as the escalation point for customer risk decisions, including approval of higher-risk onboarding and periodic review outcomes.
- Review enhanced due diligence files for politically exposed persons, higher-risk jurisdictions and complex ownership structures.
- Approve transaction monitoring escalations and own scenario design, threshold calibration and post-implementation tuning.
- Assess adverse news, sanctions and name-screening matches, and determine the disposition of true and false positives.
- Set the risk-based frequency of periodic reviews and monitor completion against it.
3. Suspicious transaction reporting and law enforcement liaison
- Determine whether a report is required and file suspicious transaction reports with the Suspicious Transaction Reporting Office of the Commercial Affairs Department, within the timelines prescribed under the Corruption, Drug Trafficking and Other Serious Crimes (Confiscation of Benefits) Act 1992.
- File terrorism financing reports where the Terrorism (Suppression of Financing) Act 2002 requires them, and notify MAS where the applicable AML/CFT notice requires notification.
- Maintain the internal referral, assessment and decision record for every escalation, including decisions not to report.
- Manage requests for information from law enforcement agencies, MAS and partner financial institutions, and control the tipping-off risk arising from those requests.
- Administer account restrictions, holds and exits arising from AML/CFT decisions.
4. Compliance monitoring and testing programme
This is the expanded element of the role. The holder owns the annual compliance monitoring and testing plan for ADDX Pte. Ltd.
- Design and maintain the annual risk-based compliance monitoring and testing plan, and obtain approval for it from the Head, Group Legal & Compliance.
- Execute testing across market conduct, licensing and the Representative Notification Framework, outsourcing, conflicts, personal account dealing, marketing and disclosure, and technology risk touchpoints.
- Report findings with a rating, an owner, a remediation action and a due date, and track remediation to closure.
- Prepare the periodic compliance report for senior management, internal audit and MAS inspections.
- Testing of the AML/CFT processes owned by this role must be performed by another officer in Group Legal & Compliance or by internal audit. The holder must not test controls that the holder operates.
5. Regulatory change, licensing and regulatory administration
- Monitor developments under the Securities and Futures Act 2001, the Financial Advisers Act 2001, the Payment Services Act 2019 and applicable MAS notices and guidelines.
- Conduct gap assessments against internal policies and drive the resulting changes to closure.
- Support licensing applications, variations and renewals, including drafting submissions and coordinating internal contributions.
- Administer the Representative Notification Framework, including appointments, cessations and changes of particulars, within the prescribed timelines.
- Maintain the regulatory obligations register and the AML/CFT taxonomy.
6. Regulatory engagement, audit and inspection
- Act as a first point of contact for MAS on AML/CFT matters, under the direction of the Head, Group Legal & Compliance.
- Manage MAS inspections and thematic reviews on AML/CFT and compliance monitoring, including document production and follow-up commitments.
- Coordinate internal audit and external reviewer engagements covering AML/CFT, and close out findings.
7. Policy, training and projects
- Deliver AML/CFT and regulatory compliance training to staff, the Board and, where relevant, distribution partners, and maintain training records.
- Contribute compliance requirements to system implementations, automation and process improvement projects, including screening and transaction monitoring tooling.
- Provide AML/CFT input on new products, new distribution channels and new markets before launch.
Requirements
- Bachelor's degree. A degree in law, banking, finance or business is preferred.
- Four to eight years experience in AML/CFT within a MAS-regulated financial institution. Capital markets, securities, exchange or fintech experience is preferred.
- Demonstrated experience as an MLRO, deputy MLRO or the senior AML officer of a regulated entity, including responsibility for suspicious transaction reporting decisions.
- Working knowledge of MAS Notice SFA02-N05, MAS Notice SFA04-N02, the Corruption, Drug Trafficking and Other Serious Crimes (Confiscation of Benefits) Act 1992 and the Terrorism (Suppression of Financing) Act 2002.
- Experience in designing or executing a compliance monitoring and testing programme.
- Ability to meet the MAS Guidelines on Fit and Proper Criteria.
- ACAMS, ICA Diploma or CGSS certification is advantageous.
- Strong written English. Reports must be capable of going to MAS and to the Board without rework.
- Sound judgement under time pressure, and the confidence to hold a position with the business.
