MLRO & Compliance Officer - FinTech, Brazil

At Papel Holdings, we’re not just another Fintech company. We’re on a mission to revolutionize the financial landscape. From innovative banking solutions to cutting-edge digital asset products, we’re transforming how people interact with money.   

Careers at Papel suit those who want to have an impact, who are comfortable getting uncomfortable, willing to take risks and win big. We are brave, laser-focused and have high aptitude, with a little playfulness for good measure.  If you’re someone who thrives on high accountability, possesses a start-up spirit, and flair for industry-savvy solutions, you’ll fit right in.   

If this resonates with you, you’ll have the opportunity to make a real impact and be part of something that’s changing how we interact with money and wealth.

POSITION OBJECTIVE

We are hiring a dedicated and experienced MLRO & Compliance Officer to oversee all Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) compliance efforts for our entry into the Brazilian market. This is a crucial senior role that requires expert knowledge of Brazilian financial regulations and a proven ability to implement robust compliance programs in a high-growth technology environment.

The MLRO & Compliance Officer will hold the designated leadership function required by the Central Bank of Brazil (BACEN) and will be responsible for establishing compliance framework including policies, procedures, and controls including selection of compliance tools for the end-to-end management of all financial crime risks.

This role will be sole responsible for regulatory relationship management including advising Business, IT/Technology, Operations and Risk teams on the BCB regulations and requirements.

1. AML/CTF Program Leadership & Strategy

• Designated MLRO: Act as the officially designated MLRO to BACEN, CVM, COAF, and other relevant regulatory bodies in Brazil.
• Strategy and Policy: Develop, implement, and maintain the company's comprehensive compliance framework with specific focus on AML/CTF compliance program, policies, procedures, and controls.
• Risk Assessment: Oversee the regular completion of the enterprise-wide AML/CTF risk assessment, including specific risks related to new products, geographies, and payment channels.
• Training: Develop and deliver mandatory AML/CTF training programs for all employees, ensuring a strong culture of compliance throughout the organization.

2. Regulatory Reporting & Oversight

• Regulatory Liaison: Manage regulatory inquiries, inspections, and audits from BACEN and COAF, ensuring a smooth and compliant process. Responsible for translating existing EMI license into an operational business in line with BCB regulations by advising relevant functions on the regulatory requirements.
• Suspicious Activity Reporting (SARs): Lead the investigation, documentation, and filing of all Suspicious Activity Reports (SARs) or equivalent reports with the Council for Financial Activities Control (COAF) in a timely and accurate manner.
• System Integrity: Oversee the performance and effectiveness of transaction monitoring, screening, and case management systems, driving improvements in fraud detection and alert reduction.

3. Know Your Customer (KYC) and Enhanced Due Diligence (EDD)

• KYC Operations: Set policy and procedure for the Customer Due Diligence (CDD) and KYC onboarding process and systems configurations ensuring compliance with evolving Brazilian requirements.
• Complex Cases: Manage and approve high-risk customer profiles and Enhanced Due Diligence (EDD) procedures, including those for Politically Exposed Persons (PEPs) and complex legal structures.
• Sanctions Screening: Ensure all customers and transactions are effectively screened against local and international sanctions lists and proper policies and systems are deployed to ensure robust screening controls

4. Cross-Functional Collaboration & Governance

• Report directly to the executive leadership team and the Board of Directors on the status of the AML/CTF program and material risks.
• Collaborate closely with the Operations Director to embed compliance requirements into day-to-day operational processes, including those related to the Electronic Money Institution (EMI) framework.
• Work with the Product and Engineering teams to ensure all new features and platform changes comply with AML/CTF rules by design.

Requirements

• 8+ years of experience in financial crime compliance, with a significant portion in a Money Laundering Reporting Officer (MLRO)  role within the fintech or financial sector, preferably with an Electronic Money Institute (EMI).
• Significant experience of dealing directly with applicable regulators in Brazil
• Expert-level knowledge of the Brazilian regulatory framework, specifically BACEN Circulars, COAF regulations, and financial crime laws.
• Proven experience developing and leading an AML/CTF program for an Electronic Money Institution (EMI) or a similar regulated payments entity is highly desirable.
• Strong leadership skills with the ability to manage a team and drive consensus across different business units.
• Exceptional investigation, analytical, and report-writing skills.
• Fluency in both Portuguese and English is required for effective communication with local regulators and international management.
• Relevant certification (e.g., ACAMS, ICA Diploma) is a significant advantage.

• Competitive salary and package