Deputy Head of Transaction Monitoring

The Deputy Head of Transaction Monitoring is a senior 2LOD leadership role responsible for the execution, oversight, and continuous transaction monitoring framework across all regulated entities. The role sits within the Group Financial Crime & Compliance function and reports directly to the Head of Transaction Monitoring (TM).

The TM team is being built from the ground up and the Deputy Head is a foundational hire. The successful candidate will play a direct role in shaping how the function operates, establishing its culture, and setting the standard for how TM is executed across the Group. The decisions made and ways of working established in the early months of this team will define its trajectory.

The TM function is mid-build across detection capability, operating model, and platform infrastructure. The Deputy Head will drive delivery across a complex, multi-jurisdictional operating model - translating regulatory expectations into working controls, challenging first-line frameworks with credibility and precision, and providing structured, evidence-based oversight of TM risk across the Group.

All accountabilities are exercised on the direction of the Head of TM, or independently where the Head of TM is unavailable and the matter cannot be deferred without breaching a regulatory or operational obligation. The Head of TM retains ownership of the framework, regulatory relationships, and strategic decision-making. In the absence of the Head of TM, the Deputy will provide full operational continuity, maintaining oversight, escalation, and regulatory responsiveness across the Group

Responsibilities

TM Framework & Policy

• Shape and evolve the Group TM framework with the Head of TM - policies, procedures, rule design methodology, threshold calibration, and the quality assurance regime.
• Review and challenge Scenario Engineering outputs, rule specifications, threshold proposals, and back-testing results ahead of Head of TM sign-off.
• Own the quality bar for QA and Governance outputs, ensuring they meet the standard expected by senior management and regulators.
• Shape rule change proposals and threshold recalibrations through the change management process.
• Drive TM minimum standards across entities, partnering with local Heads of Compliance to close gaps.

Delegated Authority & Decision-Making

Hold formal delegated authority from the Head of TM, stepping into the primary TM decision-maker role whenever they're unavailable and a decision can't wait. In this capacity, you will:

• Approve withdrawal holds, account restrictions, and alert escalations.
• Review L3 SAR referral packs for completeness and evidential sufficiency before they go to the entity MLRO.
• Approve interim rule threshold changes that can't be deferred, recording the rationale for the Head of TM to confirm on their return.
• Deputise fully for the Head of TM during leave or absence, holding full decision-making authority within the governance framework for that period.

Regulatory Engagement

Working under the Head of TM's direction, and independently when they're unavailable, you will:

• Support the Head of TM in managing regulator relationships on TM matters.
• Respond to supervisory queries, attend regulatory meetings, and represent the TM function at inspections.
• Support the preparation and delivery of regulatory submissions, responses to supervisory feedback, and remediation communications.
• Coordinate with entity MLROs and Heads of Compliance on jurisdiction-specific TM requirements.

Team Leadership

• Provide day-to-day leadership and line management of TM specialist teams, alongside the Head of TM.
• Lead recruitment, onboarding, and development of TM analysts across pillars.
• Chair TM governance meetings, including in the Head of TM's absence.
• Act as the senior escalation point for analysts, bringing decisions to the Head of TM where needed.
• Drive risk culture across the TM function through visible leadership, consistent challenge, and clear communication.

Governance & Oversight

• Uphold the governance boundary between TM compliance decisions and commercial interests, escalating to the Group Head of Compliance and Regulatory Risk if the Head of TM is unavailable to resolve a conflict.
• Ensure 1LOD Alert Operations operates within the framework set by 2LOD, escalating any breach to the Head of TM.
• Maintain audit-ready documentation across all TM governance activity.
• Act as a senior escalation point for material TM issues, control failures, and emerging risks across all entities

Requirements

• Extensive experience in financial crime compliance, with at least 3 years in a senior TM role (team lead, deputy head, head of TM, or equivalent) within a regulated financial services firm.

• Experience in the CFD, forex, or leveraged derivatives sector, or with investment firms offering similar products.

• Demonstrable experience making autonomous decisions on TM matters: alert escalation, SAR filing recommendations, account restriction approvals, and rule threshold adjustments.

• Experience engaging directly with the FCA or another Tier 1 regulator (CySEC, ASIC, MAS, BaFin) on TM or financial crime matters, including responding to supervisory queries and attending regulatory meetings.

• Experience with TM framework design or significant enhancement, including rule design methodology, threshold calibration, and quality assurance.

• Working knowledge of AML/CTF regulatory requirements in at least two of: UK (FCA/MLR 2017), EU/Cyprus (AMLD/CySEC), Australia (AML/CTF Act/AUSTRAC), UAE (CBUAE).

• Experience managing or overseeing a team of financial crime or TM specialists.

• Strong written and verbal communication: the role produces materials for senior management, the CCO, the Board, and regulators