Compliance Officer & Money Laundering Reporting Officer (MLRO)

1. Role Purpose

The Compliance Officer & Money Laundering Reporting Officer (MLRO) is responsible for establishing, maintaining, and overseeing an effective compliance and AML/CFT framework for the Category 2 Investment Firm. The role ensures the firm complies with all applicable CBB regulations, laws, and internal policies, while promoting a strong culture of compliance and integrity. This is a key controlled function under the CBB’s Approved Persons regime.

2. Key Responsibilities
2.1 Compliance Framework & Oversight

• Design, implement, and continuously enhance the firm’s Compliance Policy, Compliance Manual, and related procedures in line with CBB Rulebook Volume 4 requirements.
• Monitor and advise the Board and senior management on compliance with CBB regulations, including Modules AU, HC, BC, CA, RM, CL, FC, and any other applicable modules.
• Conduct regular compliance risk assessments and maintain an up-to-date compliance risk register.
• Develop and deliver compliance training programmes for all staff, including induction and ongoing awareness sessions.
• Review and approve marketing materials, client communications, product offerings, and business initiatives from a compliance perspective.
• Act as the primary liaison with the Central Bank of Bahrain on all compliance-related matters and regulatory correspondence.
• Prepare and submit required regulatory reports and notifications to the CBB in a timely and accurate manner.
• Investigate and report compliance breaches, and recommend appropriate remedial actions.

2.2 AML / CFT Responsibilities (as MLRO)

• Serve as the firm’s Money Laundering Reporting Officer (MLRO) in accordance with Module FC of the CBB Rulebook.
• Establish, maintain, and oversee the firm’s Anti-Money Laundering and Combating the Financing of Terrorism (AML/CFT) policies, procedures, and systems.
• Ensure effective Customer Due Diligence (CDD), Enhanced Due Diligence (EDD), ongoing monitoring, and record-keeping processes are in place.
• Receive, investigate, and report Suspicious Transaction Reports (STRs) to the relevant authorities as required.
• Conduct regular AML/CFT risk assessments and ensure the firm’s risk-based approach remains appropriate.
• Monitor sanctions screening, PEP screening, and adverse media screening processes.
• Provide regular AML/CFT training to all relevant staff.
• Submit the annual AML/CFT report and any other required reports to the Board and the CBB.

2.3 Advisory & Monitoring

• Provide independent compliance advice to the Board, CEO, and business units on regulatory matters and new initiatives.
• Conduct compliance monitoring reviews and testing of key controls across the business.
• Track and implement regulatory changes and ensure the firm remains up to date with evolving CBB requirements.
• Support the Board and senior management in maintaining an effective compliance culture.

1. Regulatory Requirements (CBB)

• Must obtain and maintain CBB Approved Person status as Compliance Officer and as MLRO (these controlled functions may be combined).
• Must be resident in the Kingdom of Bahrain.
• Must be an employee of appropriate standing within the firm.
• Must continuously satisfy the CBB’s fit-and-proper criteria (honesty, integrity, competence, experience, and reputation).
• These are Controlled Functions under Module AU of the CBB Rulebook Volume 4.

1. Qualifications & Experience

• Minimum 7–10 years of relevant experience in compliance, AML/CFT, or regulatory roles within the financial services or investment industry.
• Prior experience as a Compliance Officer and/or MLRO in a CBB-licensed entity or equivalent regulated financial institution is highly preferred.
• Strong working knowledge of CBB Rulebook Volume 4, Module FC (Financial Crime), and international AML/CFT standards (FATF Recommendations).
• Bachelor’s degree in Law, Finance, Business, or a related field is required. Professional certifications such as ICA, CAMS, CCO, or equivalent are highly desirable.

1. Skills & Competencies

• Strong knowledge of regulatory compliance frameworks and AML/CFT requirements.
• High level of integrity, independence, and professional scepticism.
• Excellent analytical, investigative, and problem-solving skills.
• Strong written and verbal communication skills, with the ability to advise senior management and the Board effectively.
• Ability to work independently while collaborating effectively with business units.
• Attention to detail and strong organisational skills.
• Ability to handle confidential and sensitive information with discretion.

1. Important Note

This position combines two Controlled Functions under the Central Bank of Bahrain’s Approved Persons regime (Compliance Officer and MLRO). Appointment is subject to prior written approval from the Central Bank of Bahrain. The successful candidate must meet and continue to meet the CBB’s fit-and-proper requirements throughout the tenure of appointment. The Compliance Officer must be resident in Bahrain.