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As Shopify seeks our EU Electronic Money Institution (EMI) license, we are looking for a strategic and experienced compliance MLRO to lead our local Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) efforts. You will be responsible for the licensing process, and, post-licensure, the day-to-day AML/CTF execution and suspicious reporting governance to ensure our local compliance program is meeting regulatory expectations.
Job Responsibility:
Lead effort to obtain EMI license in Luxembourg, including designing our AML/CTF program to align with Luxembourg's financial crimes regulations
Act as a key interface for the The Commission de Surveillance du Secteur Financier (CSSF) and other relevant authorities on financial crime topics (information requests, meetings, supervisory engagement)
Own and maintain the local entity’s risk-based AML/CTF program (risk assessment, policies, procedures, controls, and governance cadence)
Lead Luxembourgian suspicious activity governance: receive internal escalations, make SAR filing decisions, submit SARs to the Cellule de Renseignement Financier (CRF), and manage post-filing confidentiality and follow-up
Oversee Luxembourgian AML operations performance and effectiveness, including KYC/CDD/EDD standards, investigations, transaction monitoring and screening governance, and quality assurance/testing
Provide regular reporting to senior management and the entity’s board
escalate material issues promptly
Maintain audit/exam readiness and drive remediation of findings
Requirements:
Significant AML/CTF leadership experience in an EU-regulated or EU-facing financial institution (payments/e-money strongly preferred), including ownership of a risk-based AML program
Direct MLRO experience (or demonstrably equivalent responsibility) including SAR decisioning and filing and management of SAR confidentiality constraints
Strong working knowledge of EU AML expectations for payments/e-money firms, including CDD/EDD, transaction monitoring, sanctions screening governance, 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 engaging with regulators/supervisors and managing audit/exam activity and remediation
Ability to meet “fit and proper” expectations for a regulated key control role (including background screening)
Ability to travel for in-person meetings, as needed (e.g., with regulators, financial partners)
Nice to have:
Experience working with EU supervisors or FIUs
familiarity with Luxembourg-specific regulatory expectations