Head of Compliance and MLRO — Partnerships & Agents

Ebury helps ambitious businesses unlock global growth, and we take the same approach with our people. We encourage innovation and movement, collaboration and problem-solving, and foster an environment where everyone can feel they belong, are valued, supported and empowered to succeed.

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Head of Compliance and MLRO — Partnerships & Agents
Ebury Madrid Office - Hybrid: 4 days in the office, 1 day working from home per week

About The Role
Ebury distributes its FX, payments, and risk-management products through ~230 Program Managers. The Program Manager channel is a major growth engine and a concentrated point of compliance, financial-crime, and operational risk: Ebury retains full licensing and KYC liability, while PMs front the client relationship and execution support.

This role is the single accountable owner of compliance and financial-crime risk arising from this channel. You will not own client-level KYC decisions or SAR filing — those remain with local onboarding teams and local MLROs — but you act as the central first-line escalation and recommendation point where PM-channel issues surface. You own the PMs themselves: who we onboard, how we monitor them, what we train them on, what registrations they need, and — critically — the program-wide data lens that identifies which PMs are systematically adding risk to Ebury's book. You design the framework that local teams execute against, and you adjudicate the PM-as-entity onboarding decisions personally as MLRO for KYD.

Key Responsibilities

MLRO for PM onboarding & KYD

Final decision-maker on PM approval, rejection, or conditional approval. Own the KYD framework — UBO verification, fit & proper of PM senior management, financial soundness, adverse media, regulatory history, sanctions, conflict-of-interest. Adjudicate all escalations from the PM onboarding workflow. Own the periodic re-KYD cycle and trigger-based refreshes.

PM registrations & local licensing

Maintain the jurisdictional map of registration and notification requirements for each PM. Own application preparation, submission, tracking, and renewal. Act as first point of contact for local regulator queries on a PM's status as a distributor.

Framework design

Own the policy stack: KYD policy, PM tiering model, annual review template, UAR escalation playbook, financial promotions standard, kill-switch and orphan-client protocols. Evolve the framework in response to industry change and lessons learned.

Program-wide data lens

Own the PM-level dashboard aggregating compliance events tagged to each PM and benchmarked against tier peers — SARs filed, waivers, exceptions, reconciliation breaks, complaints, KYC overrides, sanctions hits, marketing breaches, training compliance. Identify systemic outliers and trigger formal reviews, restrictions, retraining, or termination based on portfolio evidence.

First-line escalation and recommendation

Serve as the central escalation point for compliance and financial-crime issues surfaced through the PM channel. Investigate, form a view, and route recommendations to the relevant local MLRO, who retains decision rights and local filing obligations. Maintain a written record of escalations, recommendations made, and outcomes, and feed patterns back into the PM-level dashboard and framework.

Monitoring program

Design and run tiered ongoing monitoring (high-tier quarterly, medium semi-annual, low annual). Own the annual PM review cycle: fit & proper refresh, financial position, controls adequacy, written record. Report outcomes to the Partnership Oversight Committee and ExCo.

Training program

Design and maintain the mandatory PM training curriculum — AML, sanctions, market abuse, financial promotions, Ebury product and process. Own certification standards, completion tracking, and the suspension protocol for lapsed PMs.

PM lifecycle

Own onboarding sign-off, mid-term reviews, exit and kill-switch playbook, and orphan-client handover protocols on PM termination.

Governance & stakeholder engagement

Chair the Partnership Oversight Committee. Act as primary point of contact for the PM program in supervisory dialogue. Report to Board and ExCo on partner risk.

Required Experience

5+ years in financial-services compliance, with at least 5 years in a senior role at an EMI, payment institution, investment firm, or bank with a comparable outsourced-distribution, agent, or program-manager model.

Demonstrable experience as a named MLRO or deputy MLRO, ideally with onboarding decision-making authority.

Direct experience overseeing an introducer, agent, or program-manager network at scale — including annual reviews, fit & proper assessments, and supervisory engagement.

Experience designing and submitting registration or notification filings across multiple jurisdictions (UK and/or EU).

Track record using data and MI to drive risk-based oversight at scale — not just reviewing individual case files.

Strong working knowledge of financial-crime frameworks, outsourcing standards, and conduct expectations across the firm's operating jurisdictions.

Required Competencies

Senior judgment under pressure — comfortable making MLRO decisions that constrain commercial growth when evidence requires it.

Strong framework-thinker who can scope cleanly: knows what they own, what local teams own, and what stays unowned.

Numerate and data-fluent — can interrogate a dashboard, spot the outlier, and ask the right second question.

Influence without authority — local MLROs and partnership leaders don’t report to this role but must align with the framework.

Credible voice in senior stakeholder and supervisory dialogue.

Why Ebury?

Competitive Starting Salary with an annual discretionary bonus that truly rewards your performance from day one.

Dedicated Mentorship: Learn directly from experienced managers who are invested in your success.

Cutting-Edge Technology: Leverage state-of-the-art tailor made tools and systems that enable you to perform at your best.

Clear, Accelerated Career Progression: Defined pathways to leadership and specialist roles within Ebury.

Dynamic & Supportive Culture: Work in a collaborative environment where teamwork and personal growth are prioritized.

Generous Benefits Package: Access competitive benefits tailored to your location, which typically include health care and social benefits.

Central Office: A fantastic location with excellent transport links.

Ready to launch your career with a global FinTech?
Click the ‘Apply’ Today and discover your potential at Ebury!

About Us
Ebury delivers sophisticated, integrated solutions — business accounts, hedging, and financing — on a single platform with a seamless workflow. Our success is built on a simple premise and singular purpose: To help businesses operate and scale globally.

Since its founding in 2009, Ebury has always been a fast-growing leader in fintech. Today, we bring together 1,800+ Eburians across nearly 70 cities and we’re always looking to add to our team.

At the heart of our offering is a proprietary platform, purpose-built to help businesses seamlessly streamline and manage global cash flow. We focus on continuous product evolution and innovation to build the infrastructure for borderless growth and help our clients scale at every stage.

The opportunities at Ebury are as diverse as our people, ranging from business development to engineering roles across our tech pillars.

We believe in inclusion. We stand against discrimination in all forms and are against the intolerance of differences that makes us a modern and successful organisation. xqbhyrx At Ebury, you can be whoever you want to be and still feel a sense of belonging no matter your story.

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