Compliance Officer

PhotonPay; Johannesburg; On-site; ZAR 1,400,000 - 2,200,000; Full time

Job summary

PhotonPay is seeking a Compliance Officer / Head of Compliance for its South Africa entity. The role ensures full regulatory compliance with SA laws (NPS Act, SARB, FIC, POCA, POPIA) and acts as the local point of contact for SARB, PA, FSCA and FIC. Build and maintain a robust compliance framework from the ground up for the SA operation.

The ideal candidate has strong payments/compliance experience in SA, AML/CFT leadership, and excellent stakeholder collaboration to support fast-paced growth.

Qualifications

• 7+ years in regulatory compliance within financial services or payments.
• Experience with SARB, FIC, POCA, and POCDATARA frameworks.
• Proven ability to design and implement compliance programs from scratch.
• Fluent English with strong drafting skills for regulator correspondence.
• Experience as a FIC Act Compliance Officer or MLRO is preferred.

Responsibilities

• Oversee regulatory compliance in SA, incl. NP Act and SARB directives.
• Lead SARB authorisation applications and licence-conditions management.
• Advise local management on regulatory obligations and changes.
• Serve as primary SARB/PA/FSCA/FIC liaison; manage regulatory inquiries.
• Own regulatory reporting obligations and annual licence-related tasks.
• Maintain RMCP and AML/CFT controls; implement risk-based approach.

Skills

AML/CFT compliance

Regulatory reporting

SARB/PoPIA knowledge

Stakeholder engagement

Education

Bachelor's degree in Accounting, Business, Finance, Law

AML certifications (CAMS/ICA)

Tools

goAML reporting

Job description

PhotonPay, an AI-powered financial infrastructure, was launched in 2015. Supporting over 10 global offices and operations in 230+ countries/regions, PhotonPay Group enables efficient, secure, and integrated global payments to drive business growth with infinite ambitions.

Trusted by 200,000+ businesses worldwide to overcome banking and payment challenges, PhotonPay delivers simple, scalable, and customizable solutions – including accounts, card issuing, domestic/international payments, and embedded finance.

With licences and compliance coverage across strategic regions, PhotonPay's unified infrastructure enables businesses to accelerate product development, enhance operational efficiency, and drive sustainable growth. Photon Dance Fintech UK Limited (PDUK) holds an Authorised Payment Institution (API) licence from the UK Financial Conduct Authority; in South Africa, the Group operates through its local entity, which is authorised by the South African Reserve Bank under the National Payment System Act, 78 of 1998, and is an accountable institution under the Financial Intelligence Centre Act, 38 of 2001.

Job Description

The Compliance Officer / Head of Compliance, South Africa is responsible for ensuring that the South African entity operates in full compliance with applicable South African regulatory requirements – principally the National Payment System Act 78 of 1998 and the directives of the South African Reserve Bank (SARB), the Financial Intelligence Centre Act 38 of 2001 (FIC Act), the Prevention of Organised Crime Act 121 of 1998 (POCA), POCDATARA 33 of 2004, the Financial Sector Regulation Act 9 of 2017 (the "Twin Peaks" framework), the Protection of Personal Information Act 4 of 2013 (POPIA) and the Exchange Control Regulations – together with Group compliance standards.

The role holder acts as the entity's designated Compliance Officer for FIC Act purposes and as the local point of contact for the SARB, the Prudential Authority, the FSCA and the Financial Intelligence Centre (FIC). He or she supports local management and the Group Chief Compliance Officer in maintaining a robust compliance framework proportionate to the firm's risk profile and licence permissions, and is expected to build that framework largely from the ground up as the Group establishes its South African operation.

The ideal candidate will be a confident self-starter with strong interpersonal and organisational skills, sound judgement, and demonstrable experience in payments or financial services compliance and AML in a South African regulated environment, with the ability to engage and partner with the business proactively in a fast-paced and engaging environment.

Job Responsibilities

1. Regulatory Compliance & Governance

• Maintain and oversee the entity's compliance framework in line with the National Payment System Act and SARB directives, the SARB's activity-based authorisation framework for payment institutions (payment activities, minimum capital, fit-and-proper and reporting requirements), and the rules of the payment system management body (PASA) and relevant clearing houses.
• Lead and project-manage the SARB authorisation application and any variation or extension of licensed activities, including fit-and-proper submissions, organisational and governance requirements, safeguarding and capital evidence, and ongoing monitoring of licence conditions.
• Advise the local board / managing director and Group senior management on regulatory obligations, regulatory change and emerging risks; prepare compliance reporting to the local board and the Group Risk and Compliance Committee.
• Act as the primary point of contact with the SARB (National Payment System Department), the Prudential Authority, the FSCA and the FIC – responding to regulatory enquiries, information requests, on-site inspections and thematic reviews.
• Own regulatory reporting obligations, including SARB prudential and quarterly returns, licence-condition reporting, change-in-control notifications and material-change notifications.

2. AML/CFT/CPF Oversight under the FIC Act

• Act as the entity's designated Compliance Officer under the FIC Act, with ownership of the Risk Management and Compliance Programme (RMCP) required by section 42 – develop, document, maintain, obtain senior management approval, and review it at least annually.
• Implement and maintain AML/CTF and counter-proliferation-financing policies, procedures and controls proportionate to the entity's activities, supported by an institutional ML/TF/PF risk assessment.
• Oversee customer due diligence and enhanced due diligence, beneficial ownership identification and verification (including checks against the CIPC beneficial ownership register), ongoing monitoring, transaction monitoring and rule tuning, sanctions screening and PEP controls.
• Decide on and submit regulatory reports to the FIC through goAML within the statutory deadlines: suspicious and unusual transaction reports (section 29 – within 15 business days of becoming aware), cash threshold reports (section 28 – cash transactions above R49,999.99, within 3 business days), terrorist property reports (section 28A) and international funds transfer reports (section 31).
• Maintain the tipping-off prohibition, five-year record-keeping and FIC registration (section 43B), including goAML user and role administration.
• Ensure compliance with targeted financial sanctions under POCDATARA and United Nations Security Council resolutions, and with FIC directives and public compliance communications.
• Maintain a robust suspicious-activity escalation path from front-line staff to the Compliance Officer, and act as the escalation and decision point on all internal STR referrals.

3. Safeguarding of Client Funds

• Oversee compliance with the SARB's client-fund safeguarding requirements: segregation of client funds in trust or segregated accounts at approved banks, daily reconciliation and record-keeping, full (100%) liquidity cover for any e-money float, and the prohibition on lending or investing client balances.
• Maintain safeguarding policies and procedures, perform periodic safeguarding reviews and reconciliations, and ensure the entity is audit- and inspection-ready at all times.
• Ensure appropriate escalation of safeguarding shortfalls or breaches in line with Group policy, including notification to the SARB where required.

4. Market Conduct, Data Protection & Exchange Control

• Support conduct-risk management under the Twin Peaks framework and applicable FSCA conduct standards, promoting fair treatment of customers and clear disclosure of charges, fees and exchange rates.
• Act as, or support, the entity's Information Officer under POPIA, including lawful processing, cross-border transfer assessments for Group systems and data‑breach response.
• Oversee exchange‑control compliance and reporting to the SARB Financial Surveillance Department for cross‑border payment flows, working with authorised dealers, the Group treasury team and corridor partners.
• Support Group licensing, passporting and new‑market entry where the South African entity is the contracting or servicing entity for African corridors.
• Draft, review and maintain local compliance policies and procedures, translating Group policies into South African requirements and documenting justified local deviations.
• Deliver FIC Act, AML/CFT, sanctions and conduct training to staff and senior management, and maintain training records to evidence effectiveness.
• Provide day‑to‑day compliance advice to product, operations and business teams on new products, payment corridors, agent and outsourcing arrangements, and changes to business models – including stablecoin and digital‑asset‑adjacent propositions where applicable.

Requirements

• Bachelor's degree in Accounting, Business, Finance, Law or a related discipline, or equivalent work experience; professional certifications in AML/CFT (e.g. CAMS, ICA) are highly desirable.
• Over 7 years of experience in regulatory compliance roles within the financial services sector, payment industry or related fields, of which at least 3 years in a South African regulated environment.
• Strong working knowledge of the National Payment System Act and SARB payment‑system directives, the SARB's authorisation requirements for payment institutions, and the FIC Act – including RMCP design and goAML reporting.
• Working knowledge of POCA, POCDATARA and the targeted financial sanctions regime, and of the Twin Peaks regulatory architecture (SARB / Prudential Authority / FSCA).
• Proven track record of implementing and managing AML/CFT compliance programmes, conducting ML/TF risk assessments, and investigating and reporting suspicious activity in line with regulatory standards.
• Prior experience as a FIC Act Compliance Officer or MLRO (or in a deputy capacity) and direct experience of SARB, PA or FIC supervisory engagement – inspections, directives, remediation and administrative‑sanction processes – is strongly preferred.
• Exposure to payment institutions, payment service providers, e‑money, remittance, acquiring or crypto asset service providers; familiarity with PASA rules, PayShap / real‑time clearing and cross‑border corridors is an advantage.
• Working knowledge of POPIA and exchange‑control reporting; awareness of the SARB's new activity‑based authorisation framework and of FATF standards (South Africa exited the FATF grey list in October 2025 and faces its next mutual evaluation in 2026/27) is an advantage.
• Strong analytical and creative problem‑solving capabilities, with the ability to operate as a sole local compliance function and build processes from scratch in a 0‑to‑1 market entry.
• Fluent English (written and spoken) is essential, with strong drafting skills for policies, board papers and regulator correspondence. Mandarin Chinese is an advantage for Group liaison; additional South African languages are welcomed.
• Proactive, results‑driven and able to take ownership of assigned work; discreet, with the integrity to escalatte uncomfortable findings.
• Existing right to work in South Africa is preferred.