Money Laundering Reporting Officer (MLRO)

• Ensure full compliance with AIFC AML/CFT and Sanctions Rules, the Kazakhstan AML/CFT Law, and all applicable regulations.
• Review the adequacy and effectiveness of AML policies and procedures and recommend improvements.
• Oversee the implementation of AML controls and procedures as established in the company’s internal documentation.

• Collect and verify client identification data before establishing business relationships.
• Conduct Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD) for high-risk clients, complex ownership structures, or when circumstances change.
• Monitor customers for Politically Exposed Persons (PEPs) and Ultimate Beneficial Owners (UBOs) status.

• Monitor transactions to identify suspicious activities or deviations from expected business patterns.
• Apply a risk-based approach in transaction analysis.
• Maintain and enhance automated monitoring systems, where applicable.

• Receive internal reports of suspicious activities from employees.
• Prepare and submit Suspicious Activity Reports (SARs) or Suspicious Transaction Reports (STRs) to the Financial Intelligence Unit (FIU) through AFSA, in line with AIFC AML Rules and the Kazakhstan AML/CFT Law.
• Maintain a register of submitted SARs/STRs and confirmations received from regulators.

• Prepare and submit the annual AML Return Form to AFSA.
• Notify AFSA of any significant AML breaches, audit findings, changes in the AML Framework, or the appointment of a new MLRO.
• Manage all correspondence and engagement with AFSA and FIU on AML/CFT matters.

• Develop and maintain the company-wide Money Laundering and Terrorist Financing Risk Assessment (ML/TF Risk Assessment).
• Identify and assess risks across customers, products, delivery channels, and jurisdictions.
• Update Customer Risk Assessments and Business Risk Assessments at least annually.

• Organize independent testing or audit (internal or external) of the AML/CFT program.
• Oversee the implementation of corrective measures based on audit findings.

• Conduct regular (at least annual) AML/CFT training sessions for all employees and management.
• Develop training materials, maintain training records, and conduct knowledge assessments.
• Ensure staff awareness of new money laundering typologies and changes in AML/CFT legislation.

• Maintain all AML-related documentation (CDD/EDD files, reports, regulatory correspondence) for a minimum of five years.
• Ensure secure and accessible storage of records for AFSA/FIU inspections.

• Represent the company in interactions with AFSA, FIU, law enforcement, and other competent authorities.
• Handle official requests and correspondence from regulators and ensure timely, accurate responses.
• Maintain professional relationships with external auditors, consultants, and regulatory bodies.

• Bachelor’s or Master’s degree in Law, Economics, Finance, or Business Administration.

• Minimum 2–3 years of professional experience in AML/CFT, financial monitoring, or compliance.
• Strong knowledge of AIFC AML Rules, AFSA Guidance, Kazakhstan AML/CFT Law, and FATF Standards.
• Professional AML certification (CAMS, ICA, or ACAMS) is mandatory or strongly preferred.

• Strong analytical and investigative skills, attention to detail, honesty, and independence.
• Excellent command of English and Russian (oral and written).
• High level of integrity and ability to handle confidential information.

HeadHunter