MLRO in UK

Paybis launched in 2014 with one goal: make crypto accessible using payment methods people already trust. Twelve years later, 6.9 million customers across 251 countries have used the platform, and $5.47 billion has moved through it. 2025 was our strongest year on record — $2 billion in volume, 266% year-on-year growth.

We are not a startup figuring out product-market fit. We are a regulated, profitable, bootstrapped business expanding into new markets — including a dual-authorisation strategy in the UK. Compliance here is not overhead. It is what makes the product sellable to regulated partners, and what keeps us operating across 180+ countries.

We are hiring a MLRO in UK to hold both the Compliance Oversight Function (SMF16) and the Money Laundering Reporting Officer Function (SMF17) for our UK entity.

This is not a process-execution role or a junior MLRO role with a senior title. This is a named Senior Management Function with personal statutory accountability under the FCA's SM&CR regime. You will be the authoritative voice on UK compliance and financial crime matters — independent enough to challenge senior management, credible enough to engage the FCA directly, and experienced enough to own the SAR process from day one.

We are pursuing a dual-authorisation strategy in the UK: FCA registration as a cryptoasset business under the Money Laundering Regulations 2017 and FCA authorisation as an Electronic Money Institution. This hire is central to making that happen.

MLRO (SMF17)

• Receiving, assessing, and filing Suspicious Activity Reports with the NCA — including consent SARs and moratorium management
• Owning the firm's AML/CTF and sanctions framework end-to-end — policies, controls, risk assessments, transaction monitoring
• Producing and presenting the Annual MLRO Report to senior management and governance bodies
• Acting as primary point of contact for the NCA and other competent authorities on financial crime matters
• Overseeing CDD, EDD, ongoing monitoring, and AML training

Compliance Oversight (SMF16)

• Establishing and maintaining the UK compliance framework and governance arrangements from scratch
• Running the Compliance Monitoring Programme — thematic reviews, compliance testing, issue remediation, management reporting
• Supporting FCA registration and EMI authorisation workstreams
• Implementing regulatory change and ensuring alignment with FCA Handbook, FCG, JMLSG, MLR 2017, POCA 2002
• Preparing Board-level compliance reporting and providing effective challenge to senior management

Must-have

• Currently FCA-approvable for both SMF16 and SMF17 — clean regulatory record, willing to be named on the Financial Services Register
• 5+ years in UK compliance and/or financial crime leadership within an FCA-regulated entity — EMI, PI, bank, or VASP
• Direct personal experience filing SARs with the NCA, including consent SARs and moratorium management — this cannot be learned on the job
• Strong working knowledge of POCA 2002, TA 2000, MLR 2017, FCA FCG, JMLSG, and OFSI sanctions
• Crypto or virtual asset compliance experience — a traditional banking MLRO without crypto exposure will not be considered
• Proven ability to independently produce Board reports, Annual MLRO Reports, regulatory submissions, and governance documentation
• Experience supporting FCA and/or HMRC registration or authorisation projects, supervisory interactions, or regulatory remediation

Nice-to-have

• Previous experience holding both SMF16 and SMF17 (or equivalent) simultaneously
• Direct FCA supervisory engagement — s165 requests, inspections, skilled person reviews
• Familiarity with UK Travel Rule obligations (SI 2023/1212)
• Blockchain analytics tools — Chainalysis, Elliptic, Scorechain, TRM Labs
• Experience across both cryptoasset and payments/e-money regulatory frameworks
• CAMS, ICA Diploma, or equivalent professional certification

30 days — Audit and initiation

• FCA approval process initiated and on track
• Full assessment of the UK compliance and financial crime framework completed
• Key stakeholders across Compliance, Legal, Product, Operations, and Senior Management met
• Material risks identified and initial remediation plan produced

90 days — Framework in place

• UK compliance and financial crime frameworks reviewed and enhanced
• Compliance Monitoring Programme implemented
• Regular reporting cadence established with Group CCO and senior management
• AML training, sanctions controls, and escalation processes operational

6 months — Fully independent

• Operating independently as SMF16 and SMF17
• Regulatory interactions and internal escalations managed without support
• Demonstrable improvements in governance, monitoring, audit-readiness, or AML effectiveness

1. Head of HR interview — FCA approvability confirmed, culture fit, motivation
2. Hiring Manager interview — regulatory depth, SAR experience, governance evidence
3. Reference checks

$5.47 billion in volume, 6.9 million customers, 266% growth in 2025 — bootstrapped, profitable, and expanding. The UK is not a side project. It is a strategic market with a dual-authorisation track already in motion.

• Named accountability, real authority — you hold SMF16 and SMF17, you own the function, you make the calls
• Build from scratch — no inherited bureaucracy, no existing team to manage around; you design the UK compliance framework
• Competitive salary plus bi-annual performance bonuses.
• Professional development budget for courses, seminars, and conferences.
• Health insurance after the probation period.
• Corporate events, team-building activities, and a supportive work environment.
• Regulated crypto at scale — one of the longest-running, most globally distributed crypto on-ramps in the market
• High autonomy — you exercise independent judgement; no micromanagement
• Remote — UK-based, work from anywhere in the UK