Finanzi is a Malta-based professional services group offering accounting, audit, compliance, corporate
services, advisory to local and international clients and immigration services through a number of
regulated entities, including a Class C Company Service Provider authorised by the MFSA.
The Role
Finanzi is hiring one compliance professional to run its AML/CFT and regulatory compliance functions and
to advise its service teams. Candidates without a prior MLRO title are welcome if they bring solid
compliance advisory and AML experience.
The purpose of the role is to keep Finanzi compliant with the PMLFTR, the FIAU Implementing
Procedures and its MFSA Class C CSP licence conditions, while helping the business take on good clients
efficiently.
It combines three functions: MLRO (AML/CFT and reporting), Compliance Officer (MFSA licence
obligations) and Compliance Advisor (day-to-day guidance to client-facing teams).
Key Responsibilities
Regulatory Liaison and Reporting
- Act as the appointed MLRO and central point of contact with the FIAU and the MFSA.
- Receive and investigate internal suspicion reports, document decisions and submit Suspicious Transaction Reports (STRs) to the FIAU in a timely manner.
- Manage regulatory submissions, including the annual REQ, questionnaires and FIAU requests for
information.
- Coordinate regulatory inspections, thematic reviews and external audits, and oversee any resulting
remediation.
- Prepare and present quarterly MLRO and Compliance reports and AML/CFT management
information for the Board.
Framework and Risk Assessment
- Maintain and update AML/CFT policies, procedures and controls, including periodic gap analyses.
- Oversee and update the Business Risk Assessment, the Customer and Jurisdictional Risk Assessment
methodologies, the Risk Appetite Statement and the client risk register.
- Monitor the adequacy and effectiveness of AML/CFT controls and risk management policies and the
level of adherence by staff.
- Ensure alignment with the PMLA, PMLFTR, FIAU Implementing Procedures (Parts I and II for CSPs, Accountants & Auditors and Tax Advisors), FATF Recommendations and MFSA expectations.
Due Diligence and Monitoring
- Review and approve CDD and EDD files at onboarding and periodic review, obtaining senior
management approval for high-risk and PEP relationships.
- Approve or refuse high-risk clients, and recommend exiting relationships where risk cannot be
mitigated.
- Assess source of wealth and source of funds, including through financial statements, contracts and
transaction documents.
- Oversee ongoing monitoring, sanctions and PEP screening, adverse-media screening and enhanced
oversight of high-risk clients.
- Advise on red flags in client records, unusual transactions and gaps between activity and declared
business.
- Provide guidance to client-facing teams on AML/CFT requirements.
CSP Compliance
- Ensure ongoing compliance with the Company Service Providers Act, the MFSA CSP Rulebook and
the conditions of Finanzi’s Class C licence.
- Design and run an annual, risk-based Compliance Monitoring Programme, and track findings to
closure.
- Maintain the Compliance Manual and related policies: conflicts of interest, outsourcing, record
keeping, complaints and breach reporting.
- Monitor directorship and company secretary appointments held by Finanzi officers, including time
commitment, conflicts and the real oversight each role requires.
- Assess and record breaches and incidents, and notify the MFSA where required.
- Carry out due diligence on outsourced service providers and review the related agreements.
- Monitor regulatory developments in Malta and the EU, and assess their impact on Finanzi.
Training and Continuous Improvement
- Deliver AML/CFT training across the organisation, maintain training logs and promote a strong
compliance culture.
- Monitor regulatory developments, including the EU AML package and AMLA, and update internal
frameworks accordingly.
- Oversee Deputy MLRO or Designated Employee cover arrangements.
Requirements
- Degree in Law, Finance, Accountancy, Business or a related field.
- Professional AML/CFT certification (ICA or ACAMS) is considered an asset.
- At least 5 years in AML/CFT or regulatory compliance in a subject person in Malta, such as a CSP,
trustee, accounting or audit firm, bank or financial institution. Being already approved by MFSA as
MLRO is an asset but equivalent hands-on AML/CFT and compliance advisory experience is
accepted.
- Strong working knowledge of the PMLA, PMLFTR, FIAU Implementing Procedures, EU AML
Directives and the CSP Rulebook.
- Experience writing or reviewing AML/CFT policies, risk assessments and Board-level reports.
- Ability to meet the MFSA fitness and properness standard.
- Strong analytical, investigative and written communication skills, particularly in regulatory
correspondence.
- Holds firm on AML/CFT decisions under commercial pressure, while explaining them clearly to
partners and clients.
- Applies a genuine risk-based approach rather than one rule for every case.
High integrity, sound judgement, strict confidentiality and the ability to work independently.
What We Offer
- Remuneration package of circa EUR 65,000 per annum, commensurate with experience.
- Two days of remote working per week following the probationary period.
- Private health insurance following the probationary period.
- Dedicated parking space.
- Annual performance reviews.
- Sponsored AML/CFT training and continuous professional development.