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UK Crypto MLRO Manager



London, UK
Posted on Tuesday, September 26, 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 Crypto MLRO Manager 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 (AML) is compliant in relation to the crypto business and to ensure that any non-compliance is addressed or escalated to the PPUK Audit, Risk, Compliance & Conduct Committee (ARCC) and/or PPUK Board where required. As a member of PPUK’s second line of defence Risk and Compliance team, you will report directly into the second line of defence UK Chief Risk & Compliance Officer (CRCO)CRCO, with the ability to escalate any Financial Crime (e.g., AML, Sanctions and Anti-Bribery and Corruption), in relation to the crypto business to the PPUK ARCC and PPUK Board.

Job Description:
  • Develop, implement, and manage UK ML and TF financing policy and procedures, monitoring, and oversight programme (to include PayPal’s global policies and procedures where they apply to the PPUK) in line with evolving statutory and crypto regulatory obligations.
  • Work closely with colleagues based across the globe (e.g., PayPal’s Blockchain, Crypto, and Digital Currencies (BCDC) business unit) and relevant third parties to ensure that PayPal’s financial crime controls are designed and operating as per UK crypto regulatory requirements.
  • Support and coordinate management focus on ML and TF crypto-related risk applicable to PPUK.
  • Assist PPUK management in developing and maintaining an effective ML and TF crypto 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 first line of defence.
  • Ensure annual business risk assessments for financial crime, Sanctions, and Anti-bribery and Corruption (pertaining to UK crypto services) are conducted effectively.
  • Prepare the annual Money Laundering Risk Officer (MLRO) report in collaboration with the global PayPal business, using findings and outputs from third line of defence 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’s cryptocurrency services.
  • In consultation with management and the first line of defence from across PayPal, create and maintain the ML risk-based approach and risk assessment for PPUK’s crypto consumers, products, and services.
  • Establish and maintain appropriate financial crime risk-based monitoring processes proportionate to PPUK’s operations, scale, nature, and complexity as it relates to crypto services.
  • Document PPUKs financial crime risk-based strategies and the basis for crypto-focused risk assessment and monitoring.
  • Ensure immediate investigation of all internal crypto-related Suspicious Activity Reports (SARs) received by PayPal’s Global Financial Crimes (GFC) and Consumer Protection (CP) team.

Additional Attributes:

  • A successful track record operating at a senior level within a regulated financial services business
  • Experience leading and managing First and/or Second line AML teams
  • Excellent knowledge of UK Financial Crime obligations and methodology
  • Understanding of and passion for the crypto, blockchain and Web3 space
  • Deep knowledge of the UK regulatory environment, regimes, and requirements.
  • Excellent UK market knowledge of existing and competing payments products and retail financial services in the UK.
  • Experience of being an Approved Person, Senior Manager or equivalent under the FCA, PRA or any other EU regulator’s regulatory regimes would be desirable but is not essential.
  • Ability to work with a global team in a matrixed organization (e.g., understanding of and experience with solid/dotted-line reporting)

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

Who We Are:

To learn more about our culture and community visit

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 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

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 R0106913