Senior Compliance Manager and MLRO

Papaya Global is a rapidly growing, award-winning B2B tech unicorn with a mission to revolutionize the payroll and payments industry. With over $400M raised from top-tier investors, our innovative technology provides a comprehensive solution for managing global workforces, from hiring and onboarding to managing and paying employees in over 160 countries. 

About the Role 

Location : Netherlands

We are seeking an experienced compliance and financial crime professional to join Azimo B.V. as a Senior Compliance Manager and MLRO. The successful candidate will play a key role in maintaining and enhancing our regulatory compliance and financial crime framework, supporting governance activities, regulatory engagement and ongoing compliance transformation initiatives. 

This is a senior, hands-on position requiring a highly experienced compliance professional who can operate independently, provide effective challenge, and engage confidently with senior management, the Board, the Supervisory Board, auditors, and regulators. The role combines regulatory compliance, financial crime oversight, governance, and MLRO responsibilities within a fast-growing and evolving payments environment. 

Key responsibilites: 

Regulatory Compliance and Governance 

• Act as a senior member of the Compliance function, supporting the maintenance and enhancement of Azimo B.V.’s overall regulatory compliance and financial crime framework 
• Maintain oversight of applicable Dutch and European regulatory requirements and ensure these are translated into effective policies, procedures, controls, monitoring activities and governance processes 
• Lead and support regulatory compliance risk assessments and thematic reviews to identify, assess, monitor and mitigate compliance risks 
• Own and oversee the Compliance Monitoring Program 
• Monitor regulatory developments and assess their impact on the business, ensuring timely implementation of regulatory changes 
• Support Senior Management, the Board, and the Supervisory Board in meeting their regulatory responsibilities through effective reporting, escalation, and governance. 
• Knowledge of safeguarding requirements applicable to payment institutions, including safeguarding governance, risk management, and regulatory expectations. 

Regulatory Engagement 

• Act as a principal Compliance contact for supervisory authorities, including DNB, coordinating regulatory engagements, information and follow-up actions 
• Lead or support regulatory inspections supervisory reviews, audits and requests for information, ensuring timely, accurate and coordinated responses. 
• Coordinate the preparation of regulatory submissions, management responses and briefing materials for regulatory engagements 
• Oversee the tracking, management, and remediation of regulatory findings, audit findings, compliance issues, and supervisory actions.  
• Ensure remediation programs are appropriately designed, governed, and delivered within agreed timelines. 

Financial Crime Compliance 

• Maintain and enhance Azimo B.V.’s AML/CFT, sanctions and financial crime compliance framework 
• Provide second-line oversight and challenge the first-line teams where appropriate 
• Support the investigation and assessment of unusual and suspicious transactions, including potential reporting obligations where appropriate 
• Lead or support the enterprise-wide risk assessments 
• Serve as the appointed MLRO, maintaining oversight of the AML/CFT and sanctions framework and ensuring compliance with applicable regulatory requirements. 
• Oversee the assessment and escalation of unusual and suspicious activity, including regulatory reporting obligations and engagement with relevant authorities where required. 

Reporting and Stakeholder Management 

• Provide high-quality management information, compliance reporting and escalation material for senior management, ARCC, Board, Supervisory Board and regulators 
• Build effective relationships across Product, Payments, Treasury, Operations, Legal, Risk and Commercial Teams to provide balanced guidance 
• Support the development of a strong culture of compliance through training, awareness activities and ongoing engagement with first-line teams 
• Support the oversight of outsourced activities and third-party service providers to ensure ongoing compliance with regulatory obligations 
• Lead the ongoing development of the enterprise-wide financial crime risk assessment and associated governance processes. 

• 8+ years of experience in Compliance, Financial Crime Compliance, Risk Management, or Regulatory Affairs within a regulated payment institution, electronic money institution, bank, fintech, or other financial services environment.  
• Previous experience as an MLRO, Deputy MLRO, or in a senior financial crime oversight role within a regulated financial services organisation is strongly preferred. 
• Demonstrated experience designing, implementing, and enhancing compliance frameworks, regulatory compliance programmes, and governance processes within a regulated financial services organisation. 
• Strong working knowledge of Dutch and European regulatory requirements applicable to payment institutions, including the Wft, Wwft, PSD2, EBA Guidelines, sanctions requirements, and relevant supervisory expectations 
• Proven experience conducting compliance risk assessments, thematic reviews, compliance monitoring activities, and regulatory gap analyses. 
• Experience managing regulatory, audit, and compliance remediation programmes, including the development, implementation, and tracking of corrective action plans. 
• Demonstrated experience engaging with regulatory authorities, internal and external auditors, and other assurance functions, including coordinating responses to regulatory enquiries, inspections, and reviews. 
• Strong understanding of payment services, cross-border payment flows, safeguarding requirements, outsourcing arrangements, and associated compliance and financial crime risks. 
• Demonstrated ability to lead complex cross-functional initiatives, influence stakeholders at all levels, and deliver outcomes in a fast-paced and evolving regulatory environment. 
• Excellent written and verbal communication skills in English. Dutch language skills would be advantageous. 
• Bachelor's degree or equivalent qualification in Law, Finance, Business Administration, Economics, Criminology, or a related discipline. 
• Relevant professional qualifications such as ICA Diploma, CAMS, CGSS, or equivalent compliance and financial crime certifications are strongly preferred. 

Personal Qualities 

• High integrity, sound judgement and strong sense of accountability 
• Confidence to provide independent challenge and escalate issues appropriately. 
• Pragmatic and solution-oriented, with the ability to balance regulatory obligations and business objectives 
• Strong stakeholder management skills and the ability to influence at all levels of the organisation 
• Excellent written communication and report-writing skills, with the ability to communicate complex regulatory matters clearly and succinctly to senior stakeholders. 
• Able to thrive in a fast-paced, dynamic and evolving regulatory environment