Director, Compliance - AMLCO

Director, Compliance, AMLCO – Sydney, Australia

​​The Director, AML Compliance, AMLCO (otherwise known as Money Laundering Reporting Officer or MLRO) serves as WUFSA's formally appointed Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) Compliance Officer as mandated by and defined under the Australian AML/CTF regulatory framework. 

The role is responsible for leading the Australian AML/CTF compliance function, overseeing and coordinating the implementation and ongoing effectiveness of WUFSA's AML/CTF Program, ensuring compliance with applicable AML/CTF legislative and regulatory requirements, and supporting the identification, assessment, monitoring and management of money laundering, terrorism financing, proliferation financing, sanctions and other financial crime risks across the business.

​The role provides strategic oversight, leadership and subject matter expertise of AML/CTF governance, risk assessment, monitoring, controls, training and regulatory compliance activities. The role is responsible for ensuring AML/CTF risk considerations are embedded into business decision-making, new products, services, delivery channels and strategic initiatives. The incumbent also provides independent challenge and oversight to ensure financial crime risks are appropriately identified, assessed, managed and escalated across the organisation.

​While primarily focused on the Australian AML/CTF regulatory framework, the role is expected to lead regional AML/CTF projects across APAC, providing subject matter expertise, guidance and coaching to AML/CTF Compliance Officers and MLROs across the region.

​Role Responsibilities

REGULATORY APPOINTMENT REQUIREMENTS:

This position is the designated AML/CTF Compliance Officer for WUFSA.

The AML/CTF Compliance Officer has direct access to the WUFSA Governing Body and may escalate material AML/CTF matters independently of operational management where required to fulfil regulatory obligations. The role is responsible for maintaining an effective AML/CTF governance framework and ensuring AML/CTF obligations are communicated, implemented and monitored across the organisation.

The position holder shall: 

• Serve as the nominated AML/CTF Compliance Officer for WUFSA. 

• Act as primary contact with AUSTRAC regarding AML/CTF matters. 

• Oversee and coordinate day-to-day compliance with AML/CTF legislation (comprises the Act, Rules and other applicable regulatory guidance and requirements), applicable sanctions obligations; WUFSA AML/CTF Program and WU global AML/CTF standards. 

• Oversee the effectiveness of AML/CTF governance, risk management, and compliance controls. 

• Escalate material AML/CTF risks, breaches and deficiencies to Senior Management and the Governing Body. 

• Provide periodic AML/CTF reporting to Senior Management and relevant governance forums. 

• Formally report AML/CTF compliance outcomes and program effectiveness to the Governing Body at least annually. 

• Maintain eligibility to perform the role throughout tenure. 

• Meet all competency, authority, and independence, and fit-and-proper requirements established under WUFSA's AML/CTF Program and associated governance framework.  

AML/CTF Program Governance and Oversight

• Own and oversee the WUFSA AML/CTF Program.
• Maintain AML/CTF policies, procedures, controls and governance documentation.
• Ensure AML/CTF frameworks remain aligned with legislative requirements and regulatory expectations.
• Oversee implementation of AML/CTF controls across all designated services.
• Ensure AML/CTF documentation remains fit for purpose and current.
• Coordinate periodic reviews and updates of the AML/CTF Program.

Oversee remediation of compliance deficiencies, audit findings and regulatory issues.

AML/CTF Compliance Officer and MLRO Responsibilities

• Perform statutory responsibilities of the AML/CTF Compliance Officer.
• Act as the principal AML/CTF contact with AUSTRAC.
• Ensure compliance with all AML/CTF reporting obligations, including Suspicious Matter Reports (SMRs), Threshold Transaction Reports (TTRs), International Funds Transfer Instructions (IFTIs) and other regulatory reporting requirements.
• Oversee suspicious activity investigations, decision-making and escalation processes.
• Oversee the effectiveness of Customer Identification Program (CIP), Customer Due Diligence (CDD), Enhanced Due Diligence (EDD) and ongoing customer monitoring controls.
• Ensure AML/CTF risk considerations are incorporated into new products, services, systems, delivery channels and material business change initiatives.
• Oversee sanctions compliance controls and escalation of potential sanctions-related matters.
• Ensure AML/CTF record-keeping obligations are maintained and periodically tested.
• Oversee implementation and monitoring of remediation programs arising from audits, compliance reviews, regulatory examinations and issue management activities.
• Maintain regulatory documentation, appointment records and compliance evidence.
• Support regulatory examinations, inspections, enquiries and information requests.
• Maintain awareness of emerging financial crime typologies, regulatory developments, sanctions risks and industry best practices.

Ensure the organisation's AML/CTF obligations are effectively communicated and understood across relevant business areas.

Financial Crime Risk Management

• Oversee the effective design and execution of enterprise AML/CTF risk assessments including associated customer, product, channel and geographic risk assessments.
• Ensure effective management of financial crime risks including money laundering, terrorism financing, proliferation financing, sanctions, and fraud, based on risk assessment outcomes and controls being implemented to manage the identified risks.
• Ensure enhanced due diligence requirements are effectively implemented.
• Review and appropriately challenge other business risk assessments as required.

Escalate material financial crime risks to senior management and governance forums.

Governance, Board Reporting and Regulatory Engagement

• Prepare periodic AML/CTF compliance reporting for Senior Management, Governing Body and other governance forums. Retain ownership and control of AML/CTF Compliance Officer reports and recommendations provided to the Governing Body, ensuring material findings, risks and recommendations are communicated transparently and without inappropriate modification.
• Provide formal AML/CTF Compliance Officer reporting to the Governing Body at least annually, including:

·         Compliance with AML/CTF policies and procedures;

·         Effectiveness of AML/CTF controls in managing ML/TF risks;

·         Compliance with AML/CTF legislative and regulatory obligations;

·         Material AML/CTF deficiencies, breaches and remediation activities.

• Escalate material AML/CTF incidents, compliance breaches, significant control deficiencies, emerging regulatory concerns and material financial crime risks as required.
• Present significant compliance issues, regulatory developments, financial crime trends, breaches and emerging risks to governance forums and senior stakeholders.
• Oversee responses to internal / external audit, compliance review, independent evaluation and regulatory findings.
• Monitor closure of audit, regulatory and review findings and ensure timely remediation of identified issues.
• Maintain effective relationships with regulators, governance stakeholders and relevant internal control functions.
•  Provide strategic advice and independent challenge to support informed decision-making regarding AML/CTF and financial crime risk matters.

Ensure Senior Management and the Governing Body remain informed of the effectiveness of the AML/CTF Program and material financial crime risks.

Monitoring, Training and Program Enhancement

• Oversee AML/CTF compliance monitoring activities.
• Ensure AML/CTF training programs remain effective, current and risk based.
• Promote and maintain a strong financial crime compliance culture throughout the organisation.
• Coordinate independent review and evaluation of the AML/CTF Program at prescribed intervals.
• Monitor remediation and closure of findings arising from independent reviews.
• Report progress of remediation activities to Senior Management and the Governing Body.
• Assess emerging regulatory developments and recommend enhancements to AML/CTF controls and governance arrangements.
• Drive continuous improvement initiatives across financial crime compliance frameworks, systems and controls.

Support the development of AML/CTF capability, awareness and expertise across the organisation.

AML/CTF Governance, Appointment and Regulatory Oversight

• Maintain ongoing eligibility and suitability as the appointed AML/CTF Compliance Officer and MLRO.
• Support periodic Fit and Proper assessments and eligibility reviews.
• Maintain records evidencing appointment, eligibility and ongoing suitability.
• Ensure regulatory notifications relating to appointment, resignation, replacement or eligibility changes are completed within prescribed timeframes.
• Escalate any matter affecting continued eligibility, suitability, independence or regulatory standing.
• Ensure governance records relating to appointment remain current and available for review.

 Western Union Competencies:

• Customer Focus
  • Provides expert compliance support and guidance to business stakeholders while ensuring customer outcomes are balanced with regulatory obligations and risk management requirements.
• Management & Planning
  • Develops, oversees and enhances compliance frameworks, governance structures, policies and risk management programs.
• Business Expertise
  • Possesses extensive expertise in AML/CTF compliance, financial crime risk management, sanctions compliance and regulatory governance.
• Leadership
  • Provides strategic compliance leadership, influences senior stakeholders and drives a culture of accountability, integrity and regulatory compliance.

Core Factors:

Functional Knowledge

• Recognised subject matter expert in AML/CTF legislation, financial crime compliance, sanctions compliance, governance and regulatory engagement.

• Applies deep technical expertise and judgement to oversee AML/CTF risk management frameworks and regulatory compliance obligations.

• Possesses extensive knowledge of money laundering, terrorism financing, proliferation financing and sanctions risks relevant to financial services and payments industries.

• Maintains awareness of emerging financial crime typologies, regulatory developments, industry trends and best practices.

• Provides authoritative advice to Senior Management, governance forums and business stakeholders regarding AML/CTF obligations and financial crime risk management.

• Exercises independent judgement in complex and high-risk regulatory and compliance matters.

• Influences organisational strategy, governance and risk management outcomes through expert knowledge and thought leadership.

Area of Impact

• Direct impact on WUFSA's regulatory compliance, financial crime risk profile, governance effectiveness and regulatory relationships.

Nature of Impact

• Influences organizational compliance, risk management and regulatory outcomes through independent oversight and governance leadership.

Problem Solving

• Exercises independent judgement and advanced analytical skills to address complex regulatory, governance and financial crime matters.

MANDATORY ELIGIBILITY AND APPOINTMENT REQUIREMENTS

The incumbent must be an Australian resident and satisfy the eligibility requirements for appointment as an AML/CTF Compliance Officer under applicable AML/CTF legislation.

Competence and Capability

The incumbent will demonstrate:

• Advanced knowledge of AML/CTF legislation, regulatory requirements and industry guidance.
• Strong understanding of money laundering, terrorism financing, proliferation financing and sanctions risks.
• Ability to interpret and apply complex regulatory obligations and expectations.
• Experience designing, implementing and overseeing AML/CTF compliance frameworks.
• Experience engaging with regulators, governance forums, internal audit and external audit.
• Capability to exercise independent judgement and risk-based decision-making.
• Ability to effectively challenge business decisions where AML/CTF risks or compliance concerns exist.
• Capability to oversee AML/CTF governance, compliance monitoring, reporting and risk management activities.

Authority

The incumbent will:

• Hold a management-level position or equivalent authority within the organisation.

• Possess sufficient standing and influence to drive compliance outcomes across the business.

• Have unrestricted access to Senior Management and the Governing Body.

• Maintain direct access to the Governing Body and appropriate governance forums for the purpose of escalating AML/CTF matters independently of operational management.

• Have authority to independently escalate ML/TF risks, deficiencies, breaches and regulatory concerns.

• Have authority to challenge business decisions where AML/CTF risks are not being appropriately addressed.

• Have authority to directly engage and communicate with AUSTRAC and other relevant regulators regarding AML/CTF matters where required.

• Have unrestricted access to governance committees and the Governing Body to discharge AML/CTF Compliance Officer responsibilities.

• Have authority to request information, documentation and resources necessary to effectively discharge AML/CTF obligations.

• Be empowered to recommend corrective actions, control enhancements and remediation initiatives to address identified AML/CTF risks and compliance deficiencies.

Independence

The incumbent will:

• Operate independently and objectively in the performance of AML/CTF Compliance Officer responsibilities.

• Remain free from undue operational influence or conflicts that may impair independent judgement.

• Exercise independent judgement regarding AML/CTF risk management and compliance matters.

• Escalate AML/CTF concerns without inappropriate influence or restriction.

• Maintain sufficient independence to provide objective oversight, challenge and governance across the AML/CTF Program.

 Access to Resources

The incumbent will have access to:

• Appropriate staffing resources and subject matter expertise.

• AML/CTF systems, technology and reporting tools.

• Legal, compliance and risk management support functions.

• External professional advice where necessary.

• Information necessary to discharge responsibilities effectively.

• Ongoing training and development necessary to maintain AML/CTF competency.

• Appropriate organisational support, budget and resources to enable effective execution of AML/CTF responsibilities.

Ongoing Suitability

The incumbent will:

• Maintain eligibility to perform the role throughout tenure.

• Immediately disclose any matter that could impact ongoing suitability, independence or effectiveness in the role.

• Continue to satisfy WUFSA's AML/CTF Compliance Officer eligibility and Fit and Proper requirements. Failure to maintain these requirements may result in the incumbent no longer being eligible to perform the role of AML/CTF Compliance Officer and MLRO.

FIT AND PROPER ASSESSMENT REQUIREMENTS

Ongoing Fit and Proper Obligations

The incumbent must immediately disclose any matter that may impact suitability including:

• criminal investigations or proceedings;
• regulatory investigations or actions;
• disciplinary actions;
• material conflicts of interest;
• insolvency-related matters;
• any circumstance that could affect integrity, competence, independence or suitability.

Fit and Proper assessments may include:

• Criminal history screening.

• Regulatory enforcement and disciplinary history reviews.

• Employment and reference verification.

• Verification of qualifications, certifications and professional memberships.

• Adverse media screening.

• Conflict of interest assessments.

• Financial probity assessments where permitted under applicable laws.

• Review of competency, performance and regulatory obligations associated with the role.

Conflicts of Interest

• The incumbent must disclose any actual, potential or perceived conflict of interest which may impair their independence, objectivity or ability to perform AML/CTF Compliance Officer responsibilities.

• The incumbent must comply with WUFSA conflict management requirements and promptly notify relevant governance bodies of any material conflicts.

WUFSA may conduct periodic reassessments of the incumbent's Fit and Proper status. Continued appointment is contingent upon maintaining satisfactory Fit and Proper standing.

Role Requirements

• Minimum 10 years' experience in AML/CTF Compliance, Financial Crime Compliance, Financial Crime Risk Management, Regulatory Compliance or related disciplines.
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• Minimum 5 years' experience in senior AML/CTF compliance leadership in Australia, for example this could be acting as the AMLCO or Deputy AMLCO in a similar sized organisation, a senior leader who runs a sizable financial crime risk function in a large organisation, or demonstrated experience in acting as, or supporting, an AMLCO within a regulated financial institution, payments provider, remittance business or financial services organisation.
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• Demonstrated experience engaging directly with regulators, boards, audit committees, executive leadership teams and governance forums.
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• Demonstrated experience designing, implementing and maintaining AML/CTF frameworks, risk assessments and financial crime control environments.
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• Demonstrated experience in providing leadership on compliance remediation and transformation programs.
• undefined
• Bachelor's degree required in Law, Finance, Business, Risk Management, Accounting, Public Policy, or a related discipline. Advanced degree preferred.

• • Postgraduate qualifications in Compliance, Risk Management, Financial Crime or Law is highly desirable.

• Professional certifications such as ACAMS certification, ICA Diploma or Advanced Certificate, ACFCS Certification, or other recognised AML/CTF; compliance or financial crime certifications will be highly regarded.

Additional Skills:

• Advanced knowledge of AML/CTF, sanctions compliance, financial crime risk management, regulatory reporting, governance, controls, and audit/remediation frameworks.
• Skilled in risk assessment, policy development, compliance monitoring, and pragmatic risk-based decision-making.
• Strong executive communication, board reporting, stakeholder engagement, regulatory liaison, leadership, and influencing capabilities.

Work Shift

Western Union values in-person collaboration, problem solving, and ideation whenever possible. We believe this fosters common ways of working and supports how we execute initiatives for our customers. The expectation is to work from the office a minimum of three days a week.

BENEFITS AND OTHER DETAILS

Benefits

You will also have access to short-term incentives, accident and life insurance, and access to best-in-class development platforms, to name a few (https://careers.westernunion.com/global-benefits/). Please see the location-specific benefits below and note that your Recruiter may share additional role-specific benefits during your interview process or in an offer of employment.

Your Australia specific benefits include:

• Life / Accident Coverage
• Superannuation Plan
• Paid Time Offs
• Employee Wellness
• Global Recognition and Rewards Programs

Other Details

We are passionate about honoring our employee's identity and fostering a feeling of belonging. Our commitment is to provide an inclusive culture that celebrates the unique backgrounds and perspectives of our global teams while reflecting the communities we serve. We do not discriminate based on race, color, national origin, religion, political affiliation, sex (including pregnancy), sexual orientation, gender identity, age, disability, marital status, or veteran status. The company will provide accommodation to applicants, including those with disabilities, during the recruitment process, following applicable laws.

#LI-ES1 #LI-Hybrid

Estimated Job Posting End Date:

11-20-2026

This application window is a good-faith estimate of the time that this posting will remain open. This posting will be promptly updated if the deadline is extended or the role is filled.