Head of Financial Crime

About the Role

Tembo Money are seeking a Head of Financial Crime to spearhead the financial crime function, evolving it into a mature, robust, and effective capability. The Head of Financial Crime will be pivotal in shaping the future direction of financial crime controls, directly influencing the company's reputation for compliance, security and trust. This position is crucial in ensuring the organisation’s steadfast compliance with all pertinent UK financial crime regulations while providing robust protection to both the company and its customers against the inherent financial crime risks associated with savings and mortgage product offerings.

Key Responsibilities

• Framework Development and Implementation: The Head of Financial Crime will be responsible for the comprehensive design, development, and strategic implementation of a risk-based financial crime control framework specifically tailored to the unique risks of savings and mortgage products within the fast-paced fintech sector. This involves taking ownership of the current basic framework to build it into a robust, scalable system that meets regulatory expectations and anticipates future growth by adhering to industry best practices. The role necessitates establishing clear, well-defined policies, practical procedures, and effective controls that comprehensively address all critical aspects of financial crime, including Anti-Money Laundering (AML), Counter-Terrorist Financing (CTF), robust fraud prevention measures, and diligent compliance with all applicable sanctions regulations.
• Risk Assessment: Conduct thorough enterprise-wide financial crime risk assessments to identify, evaluate, and understand threats and vulnerabilities related to savings/mortgage products and the fintech operational model, enabling early detection and targeted mitigation.
• Policy and Procedure Management: Responsible for establishing, meticulously documenting, consistently maintaining, effectively communicating, and seamlessly implementing clear, comprehensive, and up-to-date financial crime policies, procedures, and overarching standards that accurately reflect prevailing regulatory requirements and incorporate recognised industry best practices across all relevant business areas to ensure company-wide understanding and compliance.
• AML/KYC & Fraud Oversight: The Head of Financial Crime is ultimately responsible for the strategic design, implementation, and continuous improvement of Fraud, AML and KYC programs, ensuring they meet regulatory requirements, prevent financial crime, are robust and adaptable to the company's risk profile, and include tailored risk-based CDD and EDD processes for savings and mortgage product customers whilst reducing losses to a minimal amount.
• Transaction Monitoring and Sanctions Screening: Requires expertise in selecting, implementing, and optimising transaction monitoring systems for savings and mortgage transactions (including rule establishment and threshold calibration), evaluating system options, and establishing/maintaining robust sanctions screening processes compliant with UK and international regulations for customers and transactions.
• Regulatory Compliance: Ensure full compliance with all UK financial crime laws (including Money Laundering Regulations 2017, Proceeds of Crime Act 2002, Terrorism Act 2000, and relevant FCA Handbook sections), act as the primary regulatory contact (FCA and others), and proactively monitor and implement changes based on regulatory developments and industry trends.
• Stakeholder Management: Effective collaboration and strong working relationships, both internally across product development, technology, operations, and legal to embed financial crime controls throughout the product lifecycle and business processes, and externally with regulators, law enforcement, and industry peers to align with best practices and regulatory expectations, are essential for robust financial crime risk management.
• Training and Awareness: The Head of Financial Crime will be responsible for developing, delivering, and overseeing the comprehensive implementation of a tailored financial crime training program for all employees. This program must be specifically designed to address the unique aspects of their roles and responsibilities, ultimately fostering a strong and pervasive culture of compliance throughout the organisation. The training should equip employees with the knowledge and understanding necessary to identify and report potential financial crime risks.
• Reporting and MI: Establishing and diligently maintaining robust reporting mechanisms is crucial for providing senior management and the Board of Directors with regular, insightful updates on the company’s exposure to financial crime risks, the overall effectiveness of implemented controls, and key performance indicators (KPIs) related to financial crime prevention. These reports will enable informed decision-making and oversight at the highest levels of the organisation.
• Team Leadership: As the company experiences continued growth, a key responsibility will be to strategically build and effectively lead a high-performing financial crime team. This includes providing strong mentorship, clear guidance, and fostering a supportive culture that encourages continuous professional development and improvement within the team. The Head of Financial Crime will be instrumental in shaping the skills and capabilities of the financial crime function as it evolves.