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As Shopify seeks our EU Electronic Money Institution (EMI) licence, we are looking for an experienced compliance Money Laundering Reporting Officer (MLRO) to lead our local Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) efforts. You will be responsible for supporting the licensing process, and, post-authorisation, the execution of the AML/CTF and suspicious activity programme to ensure we are meeting regulatory expectations.
Job Responsibility
Support our effort to obtain an EMI licence in Luxembourg, including providing input into the design of our AML/CTF programme to align with Luxembourg's financial crimes regulations
Implement and operationalise the local AML/CFT programme from the ground up, while partnering with the global/UK AML programme to keep standards consistent and preserve local independence
Respond to inquiries from the Commission de Surveillance du Secteur Financier (CSSF) and other relevant authorities on financial crime matters
Maintain and execute the local entity's risk-based AML/CTF programme, including the risk assessment, policies, and controls
Lead Luxembourg suspicious activity reporting: receive internal escalations, make STR/SAR filing decisions, submit reports to the Cellule de Renseignement Financier (CRF), and manage post-filing follow-up information requests
Monitor AML operations performance and effectiveness, including AML/KYC standards, transaction monitoring and screening governance, and conduct QA/testing and training
Provide regular reporting to the Head of Risk & Compliance and the entity's board
support CSSF reporting and engagement on AML/CFT matters as needed
escalate material issues promptly to management and the board
Maintain audit/exam readiness and drive remediation of AML/CTF findings
Requirements
Significant experience in an EU-regulated financial institution (payments/e-money strongly preferred), including ownership of a risk-based AML programme
Direct MLRO experience or demonstrably equivalent responsibility, such as deputy MLRO, FIU lead, or AML compliance officer with responsibility for filing decisions and submitting STR/SARs
Strong working knowledge of EU and local Luxembourg AML expectations for payments/e-money firms, including risk assessments, CDD/EDD, transaction monitoring, sanctions screening, investigations, and recordkeeping
Experience working collaboratively in building or scaling AML controls for new products, high-growth volumes, or distributed operations teams
Demonstrated ability to work effectively with a management board and to provide concise, defensible escalation and reporting
Experience responding to regulatory requests and managing audit/exam activity and remediation
Ability to meet CSSF's "fit and proper" expectations for a regulated key control role (including background screening)
Residency in Luxembourg with the ability to commute to the office for in-person meetings, as needed (e.g., with regulators, financial partners)