Compliance Officer
Job summary
KclautX is a Nigerian fintech app for crypto trading, gift card exchange, and bill payments. We need a Senior Compliance Officer to build and own our compliance function. You will manage KYC, AML monitoring, sanctions screening, STR/CTR filing, regulatory inspections, and SEC VASP licensing. Minimum 3 years in fintech/banking/crypto compliance.
Job descriptions & requirements
Responsibilities:
KYC & Customer Due Diligence:
- Review and approve flagged KYC submissions across Tier 1, 2, and 3 verification levels.
- Conduct Enhanced Due Diligence (EDD) for high-value or high-risk users.
- Manual review of borderline cases: BVN mismatches, document inconsistencies, duplicate accounts, suspicious selfies.
- Maintain user risk scoring framework (low, medium, high).
- Trigger account restrictions, transaction limits, or freezes on flagged accounts.
- Manage periodic re-verification cycles for existing users.
Transaction Monitoring & AML:
- Daily monitoring of transactions against AML thresholds (N5M individual / N10M corporate).
- Identify and investigate structuring patterns, velocity spikes, and unusual flows.
- Monitor crypto-to-naira and naira-to-crypto flows for suspicious activity.
- Maintain and refine transaction monitoring rules within KclautX systems.
- Investigate flagged accounts and document all findings with audit-ready records.
Sanctions & PEP Screening:
- Screen all new users against OFAC, UN, EU, and UK Treasury sanctions lists at onboarding.
- Continuous re-screening of existing users against updated lists.
- Politically Exposed Persons (PEP) database screening.
- Manage false positive resolution and true match escalation.
Regulatory Reporting:
- Draft and file Suspicious Transaction Reports (STRs) with the NFIU within statutory timelines.
- File Currency Transaction Reports (CTRs) for transactions above thresholds.
- Prepare SEC quarterly and annual statutory reports under VASP rules.
- Submit CBN periodic returns as required by VASP guidelines.
- File NDPC annual data protection compliance returns.
- Deliver monthly internal compliance reports to the Founder.
Regulatory Engagement:
- Serve as primary point of contact for CBN, SEC, NFIU, EFCC, and NDPC correspondence.
- Draft regulatory responses and queries (with legal counsel).
- Manage SEC VASP licensing process: application, ARIP submission, and follow-ups.
- Prepare for and manage on-site or remote regulatory inspections.
- Attend industry stakeholder forums and regulator engagement sessions.
- Maintain working relationships with relevant regulator desk officers.
Policy & Documentation:
- Draft and maintain core policies: AML/CFT, KYC, Sanctions Screening, Data Protection, Whistleblower, Conflicts of Interest, Business Continuity.
- Update policies in response to regulatory changes.
- Maintain compliance manual and standard operating procedures.
- Document audit trails for every compliance decision.
- Maintain inspection-ready document repository.
Risk Management:
- Conduct annual enterprise-wide AML/CFT risk assessment.
- Product compliance reviews before any new feature ships (new tokens, payment methods, markets).
- Vendor due diligence on all third-party service providers and partners.
- Identify emerging compliance risks and recommend controls.
- Maintain compliance risk register.
Training & Awareness:
- Deliver AML/CFT training for all KclautX employees (mandatory and periodic).
- Specific training for support agents on red flag identification.
- Onboarding compliance training for every new hire.
- Maintain training records for regulator review.
- Issue compliance bulletins on regulatory developments.
Data Protection (NDPA 2023):
- Maintain KclautX privacy policy and consent flows.
- Conduct Data Protection Impact Assessments (DPIAs) for new features.
- Handle data subject access requests (DSARs).
- Manage data breach notification protocols (72-hour rule).
- Liaise with NDPC on registration and compliance.
Internal Coordination:
- Operations Coordinator: Coordinate on transaction reconciliation, AML threshold breaches, flagged transactions, and vendor compliance reviews.
- Support Lead: Receive compliance-flagged tickets, provide guidance on compliance-sensitive user interactions, and train agents on red flag identification.
- Community Lead: Review marketing content for regulatory compliance (no misleading claims about returns, no unlicensed investment advice).
- Engineering: Coordinate on compliance system improvements, KYC automation, and transaction monitoring rule implementation.
- Founder: Brief weekly on regulatory landscape, compliance posture, and emerging risks. Coordinate on all regulatory correspondence and inspections.
- External Legal Counsel: Collaborate on SEC VASP application, regulatory responses, and complex compliance matters.
Requirements:
- Minimum 3 years of compliance experience in fintech, banking, or crypto (non-negotiable).
- ACAMS certification (Certified Anti-Money Laundering Specialist) or actively pursuing it.
- Hands-on experience drafting and submitting STRs/CTRs to the NFIU.
- Direct experience with at least one regulatory examination or inspection.
- Working knowledge of Nigerian crypto regulation: ISA 2025, SEC VASP rules, CBN VASP Guidelines, MLPPA 2022, NDPA 2023.
- Familiarity with blockchain analytics tools (Chainalysis, TRM Labs, Elliptic, or similar).
- Strong understanding of FATF Travel Rule and crypto-specific AML risks.
- Bachelor's degree in Law, Finance, Accounting, Economics, or related field.
- Excellent written English. You will draft documents that regulators read.
- Sound judgment under pressure and unimpeachable personal integrity.
Preferred Requirements:
- Background in a Nigerian fintech or tier-1 bank compliance team.
- Familiarity with the SEC's Accelerated Regulatory Incubation Program (ARIP).
- Experience drafting compliance policies from scratch.
- Existing professional relationships within CBN, SEC, or NFIU.
Remuneration: NGN 300,000 to 500,000 per month (based on experience).
Benefits:
- Direct access to the Founder and a seat at the strategic table from day one.
- Ground-floor opportunity to build the compliance function for a launching crypto fintech.
- Performance bonuses introduced after month 3 based on clear, data-driven targets.
- Access to external legal counsel for support on complex regulatory matters.
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