Compliance Manager & MLRO

Wirex; Noord-Holland; On-site; EUR 90,000 - 130,000; Full time

Job summary

InvokaPAY B.V. in Amsterdam seeks a hands-on Compliance Manager, MLRO & DPO to lead AML/CFT, data protection and governance within an early-stage payments business preparing for a Dutch licence.

Reporting to the CRCO, you will own internal suspicious-activity escalation, external reporting to FIU-NL, and act as DPO to monitor GDPR compliance and promote privacy-by-design across products and processes.

Qualifications

• 3+ years in AML/CFT at manager level in regulated finance settings.
• Hands-on AML/CFT controls expertise: KYC/CDD/EDD, monitoring, sanctions.
• Experience deputising for or working with an MLRO and reporting decisions.
• Knowledge of Dutch/EU AML rules, payment services and risk management.
• GDPR knowledge and Data Protection Officer responsibilities understood.

Responsibilities

• Act as designated MLRO and manage escalation, assessment and reporting of suspicious activity.
• Decide on external suspicious-transaction reporting to FIU-NL and maintain records.
• Oversee AML/CFT controls, risk assessments, monitoring and escalation.
• Maintain AML/CFT policies, risk assessments and MI for governance bodies.
• Provide advice, training and challenge to the business on compliance matters.

Skills

AML/CFT

Financial crime

Enterprise risk

GDPR

Regulatory reporting

Data protection

Education

ICA

ACAMS/CAMS

CIPP/E

Job description

One of our group businesses, InvokaPAY B.V., an Amsterdam-based payments company, is building its team ahead of its DNB license. Wirex is proud to share these opportunities with our network.

Please note:this role is with InvokaPAY, not Wirex.

This is a full-time role (minimum 32 hours per week) and is open to candidates based in the Netherlands.

ABOUT INVOKAPAY

InvokaPAY B.V. is a Netherlands-based embedded payments business building an API-driven platform for card issuing and transaction processing. Our aim is to enable fintechs and digital platforms to integrate co-branded payment capabilities through scalable infrastructure, while InvokaPAY operates within a clear, robust, and proportionate regulatory framework.

InvokaPAY is preparing for authorisation as a payment institution in the Netherlands. This is an opportunity to join at an early stage and help build the controls, operating model and customer experience required for a regulated payments business designed to scale across Europe.

ROLE PURPOSE

The Compliance Manager, MLRO & DPO is a hands-on second-line role, reporting to the Chief Risk & Compliance Officer (CRCO), responsible for running InvokaPAY’s day-to-day compliance and AML/CFT program. The role provides independent oversight and challenge on AML/CFT, financial crime, and privacy, with direct access to the Management Board and Supervisory Board on MLRO and DPO matters. As designated MLRO, the role owns internal suspicious-activity escalation and external reporting to FIU-NL.

The role also supports the CRCO in operating InvokaPAY’s risk framework. As DPO, the role independently monitors GDPR compliance, advises on data-protection obligations, and acts as a contact point for the Autoriteit Persoonsgegevens.

KEY RESPONSIBILITIES

AML/CFT & MLRO responsibilities

• Act as InvokaPAY’s designated MLRO and maintain an effective internal framework for the escalation, assessment, documentation, and reporting of unusual or suspicious transactions.
• Make independent decisions on external suspicious transaction reporting to FIU‑NL and maintain complete, confidential records of decisions and supporting rationale.
• Oversee the effectiveness of AML/CFT controls, including customer risk assessment, KYC/CDD/EDD, sanctions screening, transaction monitoring and financial crime escalation.
• Own and maintain AML/CFT and financial-crime policies, risk assessments, procedures and management information, ensuring material weaknesses are identified and remediated.
• Provide specialist advice, training and challenge to the business and report material AML/CFT matters to senior governance bodies.

Risk management (supporting the CRCO)

• Support the CRCO, who retains accountability for InvokaPAY’s enterprise risk management framework, in its day-to-day operation, including maintaining the risk register, monitoring risk appetite and key risk indicators.
• Provide second-line oversight and challenge on compliance, financial crime, conduct and outsourcing risks, escalating wider risk matters to the CRCO.
• Coordinate risk and control assessments and risk-event reporting and ensure material exposures and remediation actions are tracked.
• Contribute to risk and compliance reporting to the Management Board and Supervisory Board and support regulatory engagement and supervisory reviews.
• Work with operational owners to strengthen controls without assuming first-line ownership of the risks or controls being overseen.

Data protection & DPO mandate

• Act as InvokaPAY’s designated Data Protection Officer and independently monitor compliance with GDPR and applicable Dutch data-protection requirements.
• Inform and advise InvokaPAY and its employees on data-protection obligations and promote privacy‑by‑design and privacy‑by‑default across products, processes and change initiatives.
• Advise on and monitor Data Protection Impact Assessments, records of processing, retention, data-subject rights and personal‑data breach management.
• Act as a contact point for and cooperate with the Autoriteit Persoonsgegevens and maintain appropriate access to the highest level of management.
• Monitor data‑protection training, awareness, policies and compliance testing while ensuring the DPO is not instructed on how to perform the statutory role.

Governance, independence & leadership

• Maintain direct and unfettered access to the Management Board and appropriate access/reporting to the Supervisory Board on matters within the role’s mandate.
• Provide independent challenge and elevate material concerns where management action is insufficient or risks exceed approved appetite.
• Support DNB, FIU‑NL, AP, audit and other competent‑authority engagements within the role’s remit and maintain inspection‑ready records.
• Manage outsourced compliance and financial-crime providers (such as KYC and transaction monitoring) and support the development of the compliance team as the organisation scales.
• Regularly assess whether the combined mandates remain adequately resourced and free from conflicts of interest; elevate capacity, independence or segmentation‑of‑duties concern promptly.

WHAT ARE WE LOOKING FOR

• At least 3 years’ experience at manager level in AML/CFT, financial crime and/or enterprise risk within regulated financial services, typically within 5 or more years’ relevant experience overall.
• Hands-on experience operating AML/CFT controls in practice, including KYC/CDD/EDD, transaction monitoring, sanctions screening and unusual-transaction investigations, ideally including oversight of outsourced providers.
• Experience acting as, deputising for, or working closely with an MLRO, including suspicious-transaction reporting decisions.
• Sound working knowledge of Dutch/EU AML/CFT, payment-services, sanctions and risk-management requirements applicable to payment institutions.
• Working knowledge of GDPR and the statutory role, independence and responsibilities of a Data Protection Officer.
• Experience supporting engagement with regulators, FIUs and auditors, and preparing clear management and board-level reporting.
• Demonstrated independence of judgement and the confidence to challenge and elevate material issues to the CRCO, senior management and, where required, the Supervisory Board.
• Professional fluency in English and the ability to operate effectively in the Netherlands.
• Experience within a Dutch payment institution, EMI, bank, card issuer, payment-initiation provider or embedded-payments business.
• Knowledge of DORA, PSD2 and evolving EU payments and AML frameworks, including their interaction with operational and technology risk.
• Relevant professional qualifications such as ICA, ACAMS/CAMS, CIPP/E or equivalent.
• Experience in an early-stage or rapidly scaling regulated business, ideally including a licence application or launch.
• Exposure to crypto-asset service providers (CASPs) or crypto-linked payment flows, including the related financial crime risks.
• Professional proficiency in Dutch.
• Practical knowledge and experience applying AI tools.

How You Will Work

• We are looking for a hands-on compliance professional, ready to take on the MLRO mandate, who combines independence, sound judgement and practical execution.

You will

• Act with integrity, sound judgement and personal accountability.
• Work hands-on in an early-stage environment, building and improving policies, processes and controls.
• Provide independent, evidence-based challenge to senior management and business owners.
• Maintain the authority, access and objectivity required to fulfil the MLRO and DPO mandates.
• Use data and risk judgement to support decisions, identify weaknesses and drive improvements.
• Escalate material issues early and ensure agreed actions are followed through.
• Promote transparency and accountability while balancing regulatory requirements, commercial realities and customer outcomes without compromising independence.

What We Offer

• Competitive employment package and benefits appropriate to the Netherlands.
• Opportunity to help build a regulated European payments business from an early stage.
• Significant influence over InvokaPAY’s AML/CFT, compliance, and data-protection frameworks.
• Direct exposure to senior leadership and cross-functional decision-making.
• Professional development and the opportunity to grow with the role and shape governance and controls as the business scales.

Pre-Employment Screening

All appointments are subject to satisfactory completion of pre-employment screening and background checks appropriate to the role.

These checks are mandatory for new hires and form part of InvokaPAY's governance and regulatory framework. The scope of screening may vary depending on the role, seniority, and regulatory responsibilities.

Candidates will receive relevant information about the screening process and any applicable consent requirements during recruitment.

InvokaPAY B.V. is committed to equal opportunity and to building an inclusive workplace. We welcome applications from candidates with diverse backgrounds, experiences, and perspectives.