UK MLRO - EMI
PayPal
London, UK · England, UK
Posted on Tuesday, November 14, 2023
At PayPal (NASDAQ: PYPL), we believe that every person has the right to participate fully in the global economy. Our mission is to democratize financial services to ensure that everyone, regardless of background or economic standing, has access to affordable, convenient, and secure products and services to take control of their financial lives.
Job Description Summary:
The UK MLRO will be based in the UK and will be accountable for ensuring all activity, conducted within PPUK, or globally on behalf of PPUK, related to anti-money laundering and the prevention of terrorist funding is compliant with UK expectations or ensure that any non-compliance is addressed or escalated to the Audit, Risk, Compliance & Conduct Committee (ARCC) and/or PPUK Board where required. The PPUK Board and Senior Management will ensure that the UK MLRO has the necessary authority and status, is fully independent, with access to resources and information sufficient to enable them to carry out their responsibilities. The UK MLRO will assume the PPUK Money Laundering Reporting Function (SMF 17) and Nominated Officer responsibilities. As a member of PPUK’s second of defence Risk and Compliance teams will report directly into the second line of defence Chief Risk & Compliance Officer (CRCO) with the ability to escalate any Financial Crime (AML, Sanctions and Anti-Bribery and Corruption) to the PPUK ARCC and PPUK Board.
Job Description:
Accountable for effective oversight, control, and management of PPUK policies, procedures and practices relating to UK AML and CTF issues, to include providing guidance, assistance, and challenge on PPUK’s policies, procedures and practices including those executed on behalf of PPUK by global teams and third parties that support PPUK execute its regulatory obligations.
Develop, implement, and manage UK AML and Counter Terrorist financing policy and procedures, monitoring, and oversight program (to include PayPal’s Global policies and procedures where they apply to the PPUK) in line with evolving statutory and regulatory obligations.
Work closely with colleagues based across the globe and relevant third parties to ensure that PayPal’s Financial Crime related controls are designed and operating as per UK regulatory requirements.
Support and coordinate management focus on the money laundering and CTF risk in individual business areas in PPUK.
Assist management in developing and maintaining an effective AML and CTF compliance culture for PPUK.
Ensure PPUK’s Financial Crime related risk management policies, Financial Crime risk assessment profile, and application are adequately documented by the 1st line of defense. Ensure Annual Business Risk Assessments for Financial Crime, Sanctions and Anti Bribery and Corruption are conducted effectively.
Prepare the annual MLRO report in collaboration with the global PayPal business, using findings and lessons learned from 1st,2nd 3-line assurance reviews, internal business changes and external changes to the business environment to develop a UK picture of Financial Crime risks, issues and controls across PayPal that impact PPUK.
In consultation with management and 1st line colleagues from across PayPal create and maintain the money laundering risk-based approach and the risk assessment of PPUKs customers, products, and services.
Establish and maintain appropriate Financial Crime risk-based monitoring processes proportionate to PPUKs operations, scale, nature, and complexity.
Document PPUKs Financial Crime risk-based strategies and the basis for risk assessment and monitoring.
Ensure immediate investigation of all internal SARs received by PayPal’s Global Financial Crime and Consumer Protection (GFCCP) team.
Ensure the submission of a SAR by PayPal’s Global Financial Crime and Consumer Protection (GFCCP) team to the relevant UK law enforcement agency (National Crime Agency) regarding all suspicions that have substance as required pursuant to PPUK.
Monitor and encourage staff compliance with the PPUK AML & CTF policies and monitor operations and development of the policy. Ensuring that any issues of concern are escalated to ARCC.
Provide management information and regular updated to ARCC and the PPUK Board as necessary, including an annual report each year to PPUKs Board and senior management on PPUKs compliance with its obligations.
Function as a primary point of contact for UK regulators, and in any other third-party enquiries on PPUK’s AML and CTF approach.
Ensure that all relevant staff are adequately trained in money AML and CTF prevention, that the standards and scope of the training are appropriate and that appropriate training records are kept.
Remain aware of any relevant sanctions, prohibitions, and notices. Also ensure that GFCCP management and relevant staff ensure the names of any individuals and institutions on the UK sanctions list are screened in a timely manner.
Provide sign-off on behalf of PPUK where required, to include the new product development approval and launch process for UK products; for marketing materials relating to UK products and for other policies; and for other relevant policies, procedures and practices which relate to, or impact on, PPUK.
Accountable as the UK Head of Financial Crime/MLRO & Financial Crime advisor to the PPUK Board and Senior Management.
Assist and guide the CEO and CRCO on SMCR Financial Crime related responsibilities.
Represent the interests of the PPUK, from an AML & CTF perspective, at meetings of PPUK and global Financial Crime related committees.
Participate as a member of the UK Risk & Compliance Committee with direct access to the UK ARCC and PPUK Board for escalation.
Escalate unresolved or ongoing unmitigated compliance gaps and issues to the UK Executive Committee, UK ARCC and UK Board.
Ensure emerging regulatory obligations Highlight the need to stay updated with evolving statutory and regulatory obligations, including any changes to AML and CTF legislation or guidelines.
Strengthen regulatory relationships on Financial Crime related matters: Establish a proactive approach to engage with regulatory authorities on Financial Crime related matters, not just as a point of contact but also by participating in relevant industry forums or working groups.
Set the appropriate ‘Tone from the Top’ by reinforcing, inputting to and tracking Financial Crime training and awareness.
Take personal accountability for ensuring s/he remains up to date and can evidence the required skills, knowledge, and abilities to continue to fulfil the requirements of the MLRO role.
To the extent not covered by the above, manage all UK Head of Financial Crime/MLRO associated duties effectively, including reporting obligations and the implementation of systems and controls for Anti Money Laundering, Counter Terrorist Financing, Tax Evasion facilitation prevention and other anti-financial crime activities.
Our Benefits:
At PayPal, we’re committed to building an equitable and inclusive global economy. And we can’t do this without our most important asset—you. That’s why we offer benefits to help you thrive in every stage of life. We champion your financial, physical, and mental health by offering valuable benefits and resources to help you care for the whole you.
We have great benefits including a flexible work environment, employee shares options, health and life insurance and more. To learn more about our benefits please visit https://www.paypalbenefits.com
Who We Are:
To learn more about our culture and community visit https://about.pypl.com/who-we-are/default.aspx
PayPal has remained at the forefront of the digital payment revolution for more than 20 years. By leveraging technology to make financial services and commerce more convenient, affordable, and secure, the PayPal platform is empowering more than 400 million consumers and merchants in more than 200 markets to join and thrive in the global economy. For more information, visit paypal.com.
PayPal provides equal employment opportunity (EEO) to all persons regardless of age, color, national origin, citizenship status, physical or mental disability, race, religion, creed, gender, sex, pregnancy, sexual orientation, gender identity and/or expression, genetic information, marital status, status with regard to public assistance, veteran status, or any other characteristic protected by federal, state or local law. In addition, PayPal will provide reasonable accommodations for qualified individuals with disabilities. If you are unable to submit an application because of incompatible assistive technology or a disability, please contact us at paypalglobaltalentacquisition@paypal.com.
As part of PayPal’s commitment to employees’ health and safety, we have established in-office Covid-19 protocols and requirements, based on expert guidance. Depending on location, this might include a Covid-19 vaccination requirement for any employee whose role requires them to work onsite. Employees may request reasonable accommodation based on a medical condition or religious belief that prevents them from being vaccinated.
REQ ID R0108194
Job Description Summary:
The UK MLRO will be based in the UK and will be accountable for ensuring all activity, conducted within PPUK, or globally on behalf of PPUK, related to anti-money laundering and the prevention of terrorist funding is compliant with UK expectations or ensure that any non-compliance is addressed or escalated to the Audit, Risk, Compliance & Conduct Committee (ARCC) and/or PPUK Board where required. The PPUK Board and Senior Management will ensure that the UK MLRO has the necessary authority and status, is fully independent, with access to resources and information sufficient to enable them to carry out their responsibilities. The UK MLRO will assume the PPUK Money Laundering Reporting Function (SMF 17) and Nominated Officer responsibilities. As a member of PPUK’s second of defence Risk and Compliance teams will report directly into the second line of defence Chief Risk & Compliance Officer (CRCO) with the ability to escalate any Financial Crime (AML, Sanctions and Anti-Bribery and Corruption) to the PPUK ARCC and PPUK Board.
Job Description:
Accountable for effective oversight, control, and management of PPUK policies, procedures and practices relating to UK AML and CTF issues, to include providing guidance, assistance, and challenge on PPUK’s policies, procedures and practices including those executed on behalf of PPUK by global teams and third parties that support PPUK execute its regulatory obligations.
Develop, implement, and manage UK AML and Counter Terrorist financing policy and procedures, monitoring, and oversight program (to include PayPal’s Global policies and procedures where they apply to the PPUK) in line with evolving statutory and regulatory obligations.
Work closely with colleagues based across the globe and relevant third parties to ensure that PayPal’s Financial Crime related controls are designed and operating as per UK regulatory requirements.
Support and coordinate management focus on the money laundering and CTF risk in individual business areas in PPUK.
Assist management in developing and maintaining an effective AML and CTF compliance culture for PPUK.
Ensure PPUK’s Financial Crime related risk management policies, Financial Crime risk assessment profile, and application are adequately documented by the 1st line of defense. Ensure Annual Business Risk Assessments for Financial Crime, Sanctions and Anti Bribery and Corruption are conducted effectively.
Prepare the annual MLRO report in collaboration with the global PayPal business, using findings and lessons learned from 1st,2nd 3-line assurance reviews, internal business changes and external changes to the business environment to develop a UK picture of Financial Crime risks, issues and controls across PayPal that impact PPUK.
In consultation with management and 1st line colleagues from across PayPal create and maintain the money laundering risk-based approach and the risk assessment of PPUKs customers, products, and services.
Establish and maintain appropriate Financial Crime risk-based monitoring processes proportionate to PPUKs operations, scale, nature, and complexity.
Document PPUKs Financial Crime risk-based strategies and the basis for risk assessment and monitoring.
Ensure immediate investigation of all internal SARs received by PayPal’s Global Financial Crime and Consumer Protection (GFCCP) team.
Ensure the submission of a SAR by PayPal’s Global Financial Crime and Consumer Protection (GFCCP) team to the relevant UK law enforcement agency (National Crime Agency) regarding all suspicions that have substance as required pursuant to PPUK.
Monitor and encourage staff compliance with the PPUK AML & CTF policies and monitor operations and development of the policy. Ensuring that any issues of concern are escalated to ARCC.
Provide management information and regular updated to ARCC and the PPUK Board as necessary, including an annual report each year to PPUKs Board and senior management on PPUKs compliance with its obligations.
Function as a primary point of contact for UK regulators, and in any other third-party enquiries on PPUK’s AML and CTF approach.
Ensure that all relevant staff are adequately trained in money AML and CTF prevention, that the standards and scope of the training are appropriate and that appropriate training records are kept.
Remain aware of any relevant sanctions, prohibitions, and notices. Also ensure that GFCCP management and relevant staff ensure the names of any individuals and institutions on the UK sanctions list are screened in a timely manner.
Provide sign-off on behalf of PPUK where required, to include the new product development approval and launch process for UK products; for marketing materials relating to UK products and for other policies; and for other relevant policies, procedures and practices which relate to, or impact on, PPUK.
Accountable as the UK Head of Financial Crime/MLRO & Financial Crime advisor to the PPUK Board and Senior Management.
Assist and guide the CEO and CRCO on SMCR Financial Crime related responsibilities.
Represent the interests of the PPUK, from an AML & CTF perspective, at meetings of PPUK and global Financial Crime related committees.
Participate as a member of the UK Risk & Compliance Committee with direct access to the UK ARCC and PPUK Board for escalation.
Escalate unresolved or ongoing unmitigated compliance gaps and issues to the UK Executive Committee, UK ARCC and UK Board.
Ensure emerging regulatory obligations Highlight the need to stay updated with evolving statutory and regulatory obligations, including any changes to AML and CTF legislation or guidelines.
Strengthen regulatory relationships on Financial Crime related matters: Establish a proactive approach to engage with regulatory authorities on Financial Crime related matters, not just as a point of contact but also by participating in relevant industry forums or working groups.
Set the appropriate ‘Tone from the Top’ by reinforcing, inputting to and tracking Financial Crime training and awareness.
Take personal accountability for ensuring s/he remains up to date and can evidence the required skills, knowledge, and abilities to continue to fulfil the requirements of the MLRO role.
To the extent not covered by the above, manage all UK Head of Financial Crime/MLRO associated duties effectively, including reporting obligations and the implementation of systems and controls for Anti Money Laundering, Counter Terrorist Financing, Tax Evasion facilitation prevention and other anti-financial crime activities.
Our Benefits:
At PayPal, we’re committed to building an equitable and inclusive global economy. And we can’t do this without our most important asset—you. That’s why we offer benefits to help you thrive in every stage of life. We champion your financial, physical, and mental health by offering valuable benefits and resources to help you care for the whole you.
We have great benefits including a flexible work environment, employee shares options, health and life insurance and more. To learn more about our benefits please visit https://www.paypalbenefits.com
Who We Are:
To learn more about our culture and community visit https://about.pypl.com/who-we-are/default.aspx
PayPal has remained at the forefront of the digital payment revolution for more than 20 years. By leveraging technology to make financial services and commerce more convenient, affordable, and secure, the PayPal platform is empowering more than 400 million consumers and merchants in more than 200 markets to join and thrive in the global economy. For more information, visit paypal.com.
PayPal provides equal employment opportunity (EEO) to all persons regardless of age, color, national origin, citizenship status, physical or mental disability, race, religion, creed, gender, sex, pregnancy, sexual orientation, gender identity and/or expression, genetic information, marital status, status with regard to public assistance, veteran status, or any other characteristic protected by federal, state or local law. In addition, PayPal will provide reasonable accommodations for qualified individuals with disabilities. If you are unable to submit an application because of incompatible assistive technology or a disability, please contact us at paypalglobaltalentacquisition@paypal.com.
As part of PayPal’s commitment to employees’ health and safety, we have established in-office Covid-19 protocols and requirements, based on expert guidance. Depending on location, this might include a Covid-19 vaccination requirement for any employee whose role requires them to work onsite. Employees may request reasonable accommodation based on a medical condition or religious belief that prevents them from being vaccinated.
REQ ID R0108194