Position Overview:
We are seeking a detail-oriented and experienced Compliance Analyst (2nd Line of Defence) to join our team at Bridge Building S.A. (BBSA), the EU entity for Bridge. BBSA is preparing for authorisation as an Electronic Money Institution (EMI) and a Crypto-Asset Service Provider (CASP) in Luxembourg. The successful candidate will support the MLRO and the Compliance function by providing second-line oversight, executing compliance monitoring and investigations, supporting police/law-enforcement requests, and maintaining AML/CTF policies and governance in line with Luxembourg AML/CTF laws and CSSF expectations.
Key Responsibilities:
- AML/CTF Compliance Monitoring (2LoD):
- Support, maintain, and execute an independent, risk-based AML/CTF compliance monitoring and testing programme across BBSA’s EMI and CASP perimeter.
- Perform thematic and control effectiveness reviews covering CDD/EDD, transaction monitoring, sanctions/PEP screening, recordkeeping, and governance arrangements.
- Independently assess the adequacy and effectiveness of first-line controls and document conclusions with clear ratings and recommendations.
- Issue formal findings, agree remediation actions with the First Line of Defence (1LoD), and independently validate remediation closure through follow-up testing.
- Escalate material weaknesses or control deficiencies to senior management and governance committees where required.
- Investigations and Escalations:
- Provide second-line review and challenge of higher-risk cases escalated by the first line (high-risk customers, complex typologies, sanctions/PEP matches, internal escalation); support MLRO decisioning and documentation.
- Conduct or support independent investigations triggered by red flags, audit/regulatory findings, or intelligence from partners; ensure a consistent audit trail in case management tools.
- Law Enforcement / Police Requests:
- Oversee and coordinate responses to police, law enforcement, and competent authority requests in collaboration with the MLRO and Legal.
- Provide compliance oversight to ensure responses are timely, complete, proportionate, and aligned with regulatory obligations.
- Maintain governance-level logs, metrics, and reporting relating to external authority requests.
- Assess whether information requests or intelligence received may indicate systemic control weaknesses or trigger enhanced monitoring requirements.
- Policy, Procedures and Program Maintenance:
- Draft, maintain, and periodically review AML/CTF policies, procedures, and standards for the EMI and CASP perimeter (risk rating, CDD/EDD, transaction monitoring governance, sanctions/PEP, record retention etc.).
- Contribute to the AML/CTF Business Risk Assessment and annual compliance plan; support governance committees and management reporting.
- Advisory and Training:
- Provide AML/CTF advisory support to Operations, Onboarding, Product, and Engineering teams (new products/process changes, control design, risk mitigations).
- Support the development and delivery of AML/CTF training and communications, including targeted guidance for high-risk scenarios.
- Regulatory Readiness and Reporting:
- Support responses to CSSF requests, audits, and inspections; prepare monitoring reports, management information (MI/KRIs), and remediation tracking.
- Stay up to date on changes to AML/CTF laws, CSSF guidance, and financial crime typologies relevant to payments and crypto-asset services.
Key Requirements:
- Education: Bachelor’s degree in Law, Compliance, Finance, Business Administration, or a related field.
- Experience:
- At least 4 years of experience in AML/CTF Compliance (second line of defence/compliance monitoring), preferably within an EMI/PI, CASP/VASP, bank, or regulated fintech environment.
- Demonstrated experience drafting AML/CTF policies and procedures, executing compliance monitoring/testing, supporting MLRO investigations and STR/SAR processes, and handling police/law-enforcement information requests.
- Skills:
- Strong understanding of AML/CTF governance, the three lines of defence model, and second-line compliance monitoring methodologies.
- Excellent analytical and investigative skills, with the ability to produce clear written assessments and regulatory-ready documentation.
- Ability to take full ownership of projects from conception to completion within agreed timelines.
- Proficiency with AML tooling (case management, screening, transaction monitoring); familiarity with blockchain analytics tools is an advantage.
- Strong communication skills, both written and verbal, in English; French is an asset; knowledge of German and/or Luxembourgish is an advantage.
- Certifications: Relevant certifications such as CAMS (Certified Anti-Money Laundering Specialist) or ICA (International Compliance Association) qualifications are considered an advantage.