Compliance Officer & Money Laundering Reporting Officer
Hong Kong
Business /
Hybrid /
Hybrid
About Us
Our mission is to empower everyone, regardless of their location or circumstances, to access instant and stable liquidity. Caliza enables everyone from startups to enterprises to offer real-time settlement and dollar accounts to their customers, creating opportunities for people to participate in developed economies and build wealth.We are a global team with a global product and a global mission. We bring experience from Visa, Nubank, Mercado Livre, Goldman Sachs, Upstart, Silicon Valley Bank, Intuit, and Goldfinch.
Our Backers
Our mission is backed by top-tier VCs including Better Tomorrow Ventures, Abstract Ventures, Valor Capital, Quona Capital, as well as the founders of Rappi, Remesa Online, Azimo, Anchorage, Compound, Portal Labs, and many more!
Compliance Officer & Money Laundering Reporting Officer – Job Description (For MSO Licence Application)
Position Purpose
The appointed individual will serve as both the Compliance Officer (“CO”) and the Money Laundering Reporting Officer (“MLRO”) for Caliza Hong Kong. This dual role is responsible for ensuring the company’s full compliance with the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615) (“AMLO”), the United Nations Sanctions Ordinance (Cap. 537), and all relevant guidance issued by the Customs and Excise Department (“C&ED”). The CO/MLRO will implement and oversee the AML/CFT framework, receive and assess suspicious activity reports, liaise with competent authorities, and ensure effective internal controls are in place.
Core Duties and Responsibilities
- Regulatory Compliance Oversight
- Act as the primary point of contact with the C&ED on all compliance and AML/CFT matters.
- Ensure the Licensee meets all licensing conditions and “fit and proper” requirements under AMLO Section 30(3).
- Maintain and update AML/CFT policies, procedures, and internal controls in accordance with AMLO Schedule 2 and C&ED guidelines.
- Conduct periodic AML/CFT risk assessments.
- AML/CFT Program Implementation
- Oversee Customer Due Diligence (“CDD”) and Enhanced Due Diligence (“EDD”) processes for onboarding and ongoing monitoring.
- Ensure timely sanctions screening, Politically Exposed Person (“PEP”) checks, and adverse media searches.
- Manage transaction monitoring processes to detect and review unusual or suspicious activity.
- Suspicious Transaction Reporting
- Receive and evaluate internal suspicious transaction/activity reports from staff.
- File Suspicious Transaction Reports (“STRs”) with the Joint Financial Intelligence Unit (“JFIU”) without delay and within statutory timelines.
- Maintain a secure, confidential STR register and ensure all related documentation is retained for at least 5 years.
- Respond promptly to law enforcement and regulatory enquiries.
- Monitoring & Testing
- Conduct regular reviews of business operations and AML/CFT controls to ensure effectiveness.
- Identify deficiencies and oversee remediation measures.
- Report on compliance performance and key risks to senior management.
- Recordkeeping
- Ensure all records relating to CDD, EDD, transactions, STRs, and training are retained for the statutory period under AMLO Schedule 2, Section 20.
- Training & Awareness
- Deliver AML/CFT training to staff at least annually and upon regulatory or operational changes.
- Promote a culture of compliance and reinforce awareness of “tipping off” prohibitions.
Qualifications and Competence
- Bachelor’s degree or equivalent in Law, Finance, Accounting, Business Administration, or related discipline.
- Minimum 3–5 years’ AML/CFT and compliance experience in financial services, preferably within a licensed MSO, remittance, FX, or banking environment in Hong Kong.
- Strong working knowledge of AMLO, relevant Hong Kong ordinances, and C&ED AML/CFT guidelines.
- Proven experience as a Compliance Officer and/or MLRO.
- CAMS, ACFCS, or equivalent AML/CFT professional qualification preferred.
- High integrity, strong analytical ability, and sound judgement.
Regulatory Requirement
The appointed CO/MLRO is a fit and proper person under AMLO, with sufficient seniority, authority, independence, and resources to discharge all statutory obligations effectively, and has unrestricted access to all necessary information and senior management in the performance of their duties.
AMLO Schedule 2 Reference: Section 3–6
Statutory Requirement: Customer Due Diligence (CDD) – Identify and verify customers, beneficial owners, and persons acting on behalf of customers before establishing a business relationship or carrying out a transaction.
CO/MLRO Responsibility: Oversees implementation of CDD/EDD procedures; ensures identity verification, beneficial ownership checks, and verification of authority to act. Ensures ongoing monitoring of business relationships.
AMLO Schedule 2 Reference: Section 7–10
Statutory Requirement: Ongoing Monitoring & EDD – Monitor transactions to ensure consistency with knowledge of the customer and source of funds; apply EDD in higher-risk cases.
CO/MLRO Responsibility: Reviews transaction monitoring alerts; conducts EDD for high-risk customers; approves enhanced measures for PEPs, complex structures, and higher-risk geographies.
AMLO Schedule 2 Reference: Section 15
Statutory Requirement: Failure to Complete CDD – Prohibits continuation of business without CDD completion.
CO/MLRO Responsibility: Ensures policies require refusal of transactions/relationships where CDD cannot be completed; escalates unresolved cases to senior management.
AMLO Schedule 2 Reference: Section 16–19
Statutory Requirement: Reliance on Intermediaries – Ensure any reliance meets statutory requirements.
CO/MLRO Responsibility: Approves reliance arrangements; verifies intermediaries are regulated, supervised, and meet AMLO standards; ensures reliance records are maintained.
AMLO Schedule 2 Reference: Section 20
Statutory Requirement: Recordkeeping – Maintain CDD and transaction records for at least 5 years.
CO/MLRO Responsibility: Oversees secure retention of CDD, EDD, transaction data, and STR records; ensures accessibility for C&ED review.
AMLO Schedule 2 Reference: Section 25
Statutory Requirement: Policies, Procedures & Controls – Establish, maintain, and implement internal AML/CFT systems.
CO/MLRO Responsibility: Develops and updates AML/CFT policy manual; ensures procedures meet statutory and C&ED guidelines; conducts regular reviews for effectiveness.
AMLO Schedule 2 Reference: Section 26
Statutory Requirement: Compliance Officer & MLRO Appointment – Designate responsible persons for AML/CFT compliance and suspicious transaction reporting.
CO/MLRO Responsibility: Serves as appointed CO and MLRO; ensures duties and reporting lines are documented and approved by senior management.
AMLO Schedule 2 Reference: Section 27
Statutory Requirement: Staff Screening – Implement procedures to screen employees to ensure suitability.
CO/MLRO Responsibility: Works with HR to implement fit-and-proper checks, both pre-employment and ongoing, for staff in AML/CFT-relevant roles.
AMLO Schedule 2 Reference: Section 28
Statutory Requirement: Ongoing Training – Provide AML/CFT training to staff.
CO/MLRO Responsibility: Designs and delivers annual training; updates training materials in line with legislative/regulatory changes; maintains attendance and assessment records.
AMLO Schedule 2 Reference: Section 25 & 26 (MLRO role)
Statutory Requirement: Suspicious Transaction Reporting – Receive, evaluate, and file STRs to JFIU.
CO/MLRO Responsibility: Acts as focal point for staff disclosures; assesses internal reports; files STRs promptly; maintains secure STR register; liaises with JFIU and law enforcement.
AMLO Schedule 2 Reference: UNSO (Cap. 537)
Statutory Requirement: Sanctions Compliance – Implement measures to comply with UN sanctions and freezing orders.
CO/MLRO Responsibility: Oversees sanctions screening processes; ensures updates to sanctions lists are implemented immediately; blocks/freeze assets where required and reports accordingly.
