Compliance Officer

To act as the firm’s Compliance Officer and Money Laundering Reporting Officer, hold the regulatory relationship with the CBB, keep the licence in good standing, and provide the Board with an accurate and unvarnished picture of the firm’s regulatory position at all times. This is a hands-on appointment with no team. The post-holder performs the work personally.

KEY RESPONSIBILITIES
Regulatory relationship and licence standing

1. Act as the firm’s registered Compliance Officer and MLRO, and the primary point of contact with the Central Bank of Bahrain.
2. Maintain the licence in good standing, including all conditions, notifications and approved-person records.
3. Notify the CBB of material events, changes in controllers or controlled functions, and any matter requiring prior approval.
4. Manage regulatory correspondence, information requests, inspections and any open remediation items through to documented closure.

AML / CFT programme

1. Own the firm’s AML/CFT framework in line with the CBB Rulebook, and keep policies, procedures and the business risk assessment current.
2. Perform customer due diligence, enhanced due diligence and ongoing monitoring appropriate to a firm with limited or no new business.
3. Operate sanctions and PEP screening, and investigate and escalate alerts.
4. Assess internal reports and file Suspicious Transaction Reports with the Financial Intelligence Unit where required.
5. Deliver AML/CFT awareness training to remaining staff and directors, and keep the training record.

Regulatory reporting and filings

1. Prepare and submit all periodic regulatory returns and prudential information to the CBB, accurately and on time.
2. Maintain the regulatory reporting calendar and ensure no filing is missed during the restructuring.
3. Coordinate with the finance resource so that financial and regulatory submissions reconcile.

Compliance monitoring and governance

1. Run a proportionate compliance monitoring programme and report findings to the Board.
2. Prepare the Compliance Officer’s and MLRO’s reports to the Board at the required frequency.
3. Maintain the compliance register, breach log, conflicts register and statutory records.
4. Advise the Board on regulatory obligations, including directors’ duties during restructuring.

Supporting the sale or the wind-down

1. Prepare and maintain the compliance and AML sections of any due diligence pack for a prospective buyer.
2. Respond to buyer and adviser queries on regulatory history, approvals, breaches and open items.
3. If wind-down is chosen, support the orderly surrender or cancellation of the licence — including the CBB’s requirements for an exit plan, customer and counterparty notification, record retention and final submissions.
4. Ensure records are retained and transferable in line with the Rulebook once the entity ceases to operate.

DELIVERABLES

1. The licence remains in good standing throughout the engagement, with no missed filing and no new regulatory finding.
2. A current AML/CFT framework and business risk assessment appropriate to a firm with no active business.
3. Compliance Officer and MLRO reports delivered to the Board on schedule.
4. A complete, accurate compliance and AML due diligence pack available to a prospective buyer on request.
5. A documented position on every open regulatory item, with owner and target date.
6. If wind-down proceeds: a CBB-acceptable exit plan and an orderly licence surrender.

CANDIDATE REQUIREMENTS
Essential

1. Arabic — fluent written and spoken Arabic, with professional English. This is not negotiable; the regulatory relationship is conducted in Arabic.
2. CBB status — currently holds, or is immediately eligible for, CBB Approved Person status for the Compliance Officer and MLRO controlled functions.
3. Experience — a track record as Compliance Officer and/or MLRO within a CBB-licensed financial institution, ideally an Investment Business licensee.
4. AML / CFT — practical ownership of an AML/CFT programme: risk assessment, CDD and EDD, screening, transaction monitoring, STR filing and training.
5. Regulatory reporting — hands-on preparation and submission of CBB returns, and direct handling of regulatory correspondence and inspections.
6. Availability — able to start at short notice and commit to a renewable 3-month engagement.

Desirable

1. CAMS, ICA or an equivalent recognised compliance or financial-crime qualification.
2. Experience of a licensee undergoing restructuring, sale, capital reduction or wind-down.
3. Exposure to licence surrender, deregistration or an agreed CBB exit plan.
4. Familiarity with the obligations of a firm with no active business — proportionate monitoring, dormancy and record retention.
5. Prior work with external counsel, auditors and corporate finance advisers on a transaction.

COMPETENCIES

1. Independence — reports what is true to the Board, including findings that are unwelcome during a sale process.
2. Self-sufficiency — no team, no handover and a departed executive layer; must pick up the file and run it.
3. Regulatory judgement — knows what must be notified, what must be filed and what can wait.
4. Discretion — handles shareholder, transaction and customer information appropriately.
5. Documentation — leaves a record a buyer’s adviser or the regulator can follow without explanation.