About the Role

If you want to run a financial crime function one day, this role gives you the authority and the scope to prove you can.

Payhawk operates its own electronic money institution licence in Lithuania, supervised by the Bank of Lithuania, alongside a UK licence supervised by the Financial Conduct Authority. We serve a large and international EU customer base, and we are investing in the senior compliance capability behind it.

This is a permanent, senior deputy to the MLRO, with delegated authority and real ownership. You will make the judgement calls that matter on financial crime and sanctions risk rather than passing them upward, own several of the programmes that decide how that risk is managed, and contribute to Board and regulatory reporting.

The regulatory agenda is substantial and we intend to stay ahead of it. The EU Anti-Money Laundering Regulation applies from 10 July 2027, and you will lead our readiness for it. You will own the financial crime, sanctions and fraud assessment gate for new products, working with a product organisation that ships quickly, and the ongoing due diligence programme, designing it to scale as the portfolio grows. We are also deepening our senior second-line capability in-house so you will be shaping methodology rather than reviewing someone else's.

You will report to the MLRO and work closely with the Director of Compliance, the quality assurance function, the AML operations and onboarding teams, our onboarding engineers, and the Group Chief Compliance Officer.

How we work with AI. Payhawk builds automation for a living, and we build our control functions the same way. We want someone fluent with AI as a working tool: pulling your own data and reports from connected systems, prompting well enough to get a reliable answer out of a large document set or a messy dataset, and turning repeated work into a workflow you can rerun. We will give you the tooling, the data access and the mandate to design the function around it, and any recurring manual task is yours to remove.

Responsibilities

• Act as deputy MLRO for the entity, exercising the MLRO's authority in their absence, including decisions on internal suspicious activity reports and reporting to the financial intelligence unit
• Take escalations from the first line on complex ownership structures, beneficial owner identification, politically exposed persons, adverse media, source of funds and wealth, and higher-risk business models, and decide with a documented, defensible rationale
• Own the ongoing due diligence periodic review programme and design it to scale with the portfolio
• Lead our readiness for the Anti-Money Laundering Regulation, including the gap analysis against current customer due diligence procedures and the requirements that follow
• Own the financial crime, sanctions and fraud assessment gate for new products and financial services, and keep developing it as the product range grows
• Own the financial crime and sanctions assessment of new banking partners and other third parties, and the ongoing oversight that follows
• Drive audit and risk assessment remediation to closure, with evidence that will satisfy an auditor and a supervisor
• Bring recurring second-line work in-house, including enterprise-wide and sanctions risk assessment and customer risk assessment methodology
• Design and build the automation and AI tooling that delivers all of the above, and set the standard for how the function works rather than how one queue works
• Support transaction monitoring and screening calibration, and challenge coverage where alert volumes do not track the risk profile
• Contribute to Board and regulatory reporting, including periodic MLRO, compliance and financial crime reporting
• Train and calibrate the first line, and keep raising the quality of its output

Requirements

• Genuine fluency with AI in your day-to-day work. You can pull your own data and reports from connected systems, prompt well enough to get reliable answers out of large document sets and datasets, and build a repeatable workflow from a few chained steps. You have built something yourself, whether a workflow, a set of prompts, a report or a small automation that saved you real time, and you can walk us through it
• Deep working knowledge of anti-money laundering, counter-terrorist financing and international sanctions in an EEA context, including the Lithuanian framework and Bank of Lithuania expectations
• Experience acting as, or deputising for, an MLRO, AML officer or equivalent in a licensed institution such as an electronic money institution, payment institution or bank
• Sound and fast judgement on ownership structures, beneficial owner determination, politically exposed person classification, adverse media, and source of funds and wealth
• A track record of designing controls and procedures, not only operating them, and of shortening a process rather than staffing it
• Ability to write for two audiences: a Board that wants the decision, and a supervisor that wants the evidence
• Comfortable being measured on turnaround, throughput and quality, and motivated rather than oppressed by targets
• Credible as a senior deputy to a key function holder, and willing to carry the responsibility that comes with it
• Fluent written and spoken Lithuanian and English

Nice to have

• Implementation or calibration experience with a transaction monitoring or screening platform
• Experience of a multi-jurisdiction EEA customer portfolio rather than a single national book
• Readiness work for the Anti-Money Laundering Authority or the Anti-Money Laundering Regulation, or involvement in a licence migration or re-authorisation
• SQL, Python or low-code automation skills
• Any history of building your own tools, scripts, prompts or workflows to make control work faster

Compensation - the salary range for this role is €5,000 - €6,000 gross monthly

Company Benefits

• Holiday: 30 Days paid leave
• Additional health insurance package
• Commuting allowance: We provide a €150 monthly allowance to top up your Payhawk card for commuting
• Hawks & Travel: After one year, you can work for a week from one of our international offices
• 2 annual company-wide team building days