Head of Compliance and MLRO — Partnerships & Agents

Ebury helps ambitious businesses unlock global growth, and we take the same approach with our people. We encourage innovation and movement, collaboration and problem-solving, and foster an environment where everyone can feel they belong, are valued, supported and empowered to succeed. If you’re a collaborator who wants to help transform how businesses operate globally, get in touch - we’d love to discuss how Ebury can accelerate your career so you can shape the future. Head of Compliance and MLRO — Partnerships & Agents Ebury Madrid Office - Hybrid: 4 days in the office, 1 day working from home per week About the role: Ebury distributes its FX, payments, and risk-management products through ~230 Program Managers. The Program Manager channel is a major growth engine and a concentrated point of compliance, financial-crime, and operational risk: Ebury retains full licensing and KYC liability, while PMs front the client relationship and execution support. This role is the single accountable owner of compliance and financial-crime risk arising from this channel. You will not own client-level KYC decisions or SAR filing — those remain with local onboarding teams and local MLROs — but you act as the central first-line escalation and recommendation point where PM-channel issues surface. You own the PMs themselves: who we onboard, how we monitor them, what we train them on, what registrations they need, and — critically — the program-wide data lens that identifies which PMs are systematically adding risk to Ebury's book. You design the framework that local teams execute against, and you adjudicate the PM-as-entity onboarding decisions personally as MLRO for KYD. Key responsibilities: MLRO for PM onboarding & KYD Final decision-maker on PM approval, rejection, or conditional approval. Own the KYD framework — UBO verification, fit & proper of PM senior management, financial soundness, adverse media, regulatory history, sanctions, conflict-of-interest. Adjudicate all escalations from the PM onboarding workflow. Own the periodic re-KYD cycle and trigger-based refreshes. PM registrations & local licensing Maintain the jurisdictional map of registration and notification requirements for each PM. Own application preparation, submission, tracking, and renewal. Act as first point of contact for local regulator queries on a PM's status as a distributor. Framework design Own the policy stack: KYD policy, PM tiering model, annual review template, UAR escalation playbook, financial promotions standard, kill-switch and orphan-client protocols. Evolve the framework in response to industry change and lessons learned. Program-wide data lens Own the PM-level dashboard aggregating compliance events tagged to each PM and benchmarked against tier peers — SARs filed, waivers, exceptions, reconciliation breaks, complaints, KYC overrides, sanctions hits, marketing breaches, training compliance. Identify systemic outliers and trigger formal reviews, restrictions, retraining, or termination based on portfolio evidence. First-line escalation and recommendation Serve as the central escalation point for compliance and financial-crime issues surfaced through the PM channel. Investigate, form a view, and route recommendations to the relevant local MLRO, who retains decision rights and local filing obligations. Maintain a written record of escalations, recommendations made, and outcomes, and feed patterns back into the PM-level dashboard and framework. Monitoring program Design and run tiered ongoing monitoring (high-tier quarterly, medium semi-annual, low annual). Own the annual PM review cycle: fit & proper refresh, financial position, controls adequacy, written record. Report outcomes to the Partnership Oversight Committee and ExCo. Training program Design and maintain the mandatory PM training curriculum — AML, sanctions, market abuse, financial promotions, Ebury product and process. Own certification standards, completion tracking, and the suspension protocol fo