Airwallex is establishing a Spanish Branch Office of Airwallex Netherlands B.V. ("Airwallex NL"), its Dutch-licensed e-money institution regulated by De Nederlandsche Bank ("DNB"), to support its go-to-market strategy in Spain and the broader Southern European region.
As Manager, Financial Crime Compliance & the Money Laundering Reporting Officer ("MLRO") for the Spanish Branch Office, you will be responsible for supporting the launch and ongoing compliance maintenance of the Branch Office from a financial crime, regulatory and governance perspective. You will ensure that the Spanish Branch Office operates in accordance with applicable Spanish AML/CTF requirements under Ley 10/2010 de Prevención del Blanqueo de Capitales y de la Financiación del Terrorismo ("Ley 10/2010") and its implementing regulation Real Decreto 304/2014 ("RD 304/2014"), SEPBLAC expectations and reporting requirements, applicable EU AML/CTF and sanctions frameworks, and Airwallex NL's global and regional FCC standards.
You will act as the designated Representante ante el SEPBLAC and local FCC lead for Airwallex's Spanish Branch Office, serving as a key point of contact for SEPBLAC, Banco de España, law enforcement agencies, and other relevant Spanish and EU authorities.
In addition, you will work cross-functionally with Product, Commercial, Operations, Data, and Legal colleagues to ensure our controls effectively prevent, detect, and report financial crime while enabling sustainable growth in the Spanish and Southern European markets.
Regulatory Leadership & SEPBLAC Liaison
Serve as the designated MLRO and Representante ante el SEPBLAC for the Airwallex Spanish Branch, fulfilling local AML/CTF obligations under Ley 10/2010 and RD 304/2014, as applicable to a branch of a DNB-supervised institution operating in Spain.
Act as the primary local contact for SEPBLAC and Banco de España in respect of branch-level supervisory matters, regulatory notifications, and any correspondence or inspections relating to the Spanish Branch.
Support the EMEA Regulatory and Compliance team in managing the Spanish branch notification and approval process with the relevant Spanish authorities, and maintain ongoing compliance with any conditions or requirements attached to branch authorisation.
Local Compliance Oversight
Maintain ongoing FCC oversight of the Spanish Branch Office, ensuring that local activities remain within the approved branch perimeter and aligned to Airwallex NL's regulatory permissions.
Provide local compliance advice on Spain-based sales, marketing, and account management activity, ensuring that commercial activity is appropriately controlled and consistent with the Spanish Branch Office model.
Ensure that Spanish-specific AML/CTF and sanctions requirements under Ley 10/2010 and RD 304/2014 are appropriately reflected in local policies, procedures, escalation routes, training, governance, and reporting.
Commission or facilitate the periodic external expert review of the branch's AML programme required under Article 28 of RD 304/2014, and oversee remediation of any findings.
Suspicious Activity Reporting & SEPBLAC Engagement
Oversee local processes for identifying, escalating, assessing, and, where required, reporting suspicious activity (comunicaciones de operaciones sospechosas) to SEPBLAC via its secure reporting platform, in accordance with Articles 18–19 of Ley 10/2010.
Work closely with the EMEA FCC team to ensure that Spain-related suspicious activity is identified, investigated, escalated, and documented appropriately, in compliance with the tipping-off prohibition under Article 24 of Ley 10/2010.
Provide MLRO review and decision-making input on Spain-related suspicious activity, customer exits, account restrictions, law enforcement requests, and other financial crime risk outcomes where local Spanish input is required.
Commercial Enablement & Risk Advisory
Serve as the embedded compliance partner for the Spanish commercial and sales team, providing day-to-day regulatory guidance on customer queries, product use cases, and market-specific risk scenarios relevant to the Spanish and Southern European market.
Advise on Spanish market-specific compliance considerations for complex client engagements, ensuring appropriate escalation to the EMEA FCC and KYC Ops teams where required.
Support the assessment and launch of new products or commercial initiatives targeting the Spanish market, ensuring controls are proportionate and consistent with SEPBLAC expectations and Airwallex NL's risk appetite.
Governance & Reporting
Provide regular compliance MI and reporting to Airwallex NL senior management and relevant Group Risk Committees, covering branch-level risk indicators, regulatory developments, and the effectiveness of local controls.
Maintain and update the branch's formal risk assessment under RD 304/2014, ensuring it reflects the current risk profile of the Spanish Branch and is reviewed at least annually.
Fulfil any local reporting obligations to SEPBLAC or Banco de España arising from the branch's regulatory status, in coordination with Airwallex NL's Compliance and Legal teams.
Audit & Remediation
Support the response to SEPBLAC and Banco de España branch-level supervisory enquiries, internal audits, and independent AML reviews, coordinating with the Internal Audit function where necessary.
Drive timely identification and remediation of any local compliance deficiencies, maintaining robust evidence of actions taken.

Nice to have

Experience supporting a branch office or cross-border operation of a foreign-licensed financial institution or e-money institution in Spain, with an understanding of the DNB/SEPBLAC and DNB/Banco de España supervisory interface.
Experience in payments, fintech, or e-commerce, supporting cross-border products, card issuing/acquiring, or embedded finance use cases in the Spanish and/or EU market
Recognised professional certification in compliance or financial crime (e.g., CAMS, ICA Diploma, or CGSS).
Experience operating within a regional or global FCC function and partnering across multiple jurisdictions and time zones — particularly within the EU/EEA regulatory framework.
Prior exposure to EU and UN sanctions compliance frameworks and their application in a Spanish commercial context.
Familiarity with SEPBLAC's published sectoral guidance documents, typologies, and risk indicators, and their practical application within a payments/fintech business model.
Strong ability to build relationships and influence senior stakeholders across commercial and compliance functions, balancing business enablement with regulatory rigour.
Applicant Safety Policy: Fraud and Third-Party Recruiters
To protect you from recruitment scams, please be aware that Airwallex will not ask for bank details, sensitive ID numbers (i.e. passport), or any form of payment during the application or interview process. All official communication will come from an @airwallex.com email address. Please apply only through careers.airwallex.com or our official LinkedIn page.
Airwallex does not accept unsolicited resumes from search firms/recruiters. Airwallex will not pay any fees to search firms/recruiters if a candidate is submitted by a search firm/recruiter unless an agreement has been entered into with respect to specific open position(s). Search firms/recruiters submitting resumes to Airwallex on an unsolicited basis shall be deemed to accept this condition, regardless of any other provision to the contrary.
Equal opportunity
Airwallex is proud to be an equal opportunity employer. We value diversity and anyone seeking employment at Airwallex is considered based on merit, qualifications, competence and talent. We don’t regard color, religion, race, national origin, sexual orientation, ancestry, citizenship, sex, marital or family status, disability, gender, or any other legally protected status when making our hiring decisions. If you have a disability or special need that requires accommodation, please let us know.
Education: Bachelor's Degree in Law, Finance, Business, or a related field is

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About the role

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