Manager, Financial Crime Compliance & MLRO (Germany)

About Airwallex

Airwallex is the only unified payments and financial platform for global businesses. Powered by our unique combination of proprietary infrastructure and software, we empower over 200,000 businesses worldwide – including Brex, Rippling, Navan, Qantas, SHEIN and many more – with fully integrated solutions to manage everything from business accounts, payments, spend management and treasury, to embedded finance at a global scale.

Proudly founded in Melbourne, we have a team of over 2,200 of the brightest and most innovative people in tech across 26 offices around the globe. Valued at US$8 billion and backed by world-leading investors including T. Rowe Price, Visa, Mastercard, Robinhood Ventures, Sequoia, Salesforce Ventures, DST Global, and Lone Pine Capital, Airwallex is leading the charge in building the global payments and financial platform of the future. If you’re ready to do the most ambitious work of your career, join us.

Attributes We Value

We hire successful builders with founder-like energy who want real impact, accelerated learning, and true ownership. You bring strong role-related expertise and sharp thinking, and you’re motivated by our mission and operating principles . You move fast with good judgment, dig deep with curiosity, and make decisions from first principles, balancing speed and rigor.

You're humble and collaborative; turn zero‑to‑one ideas into real products, and you “get stuff done” end-to-end. You use AI to work smarter and solve problems faster. Here, you’ll tackle complex, high‑visibility problems with exceptional teammates and grow your career as we build the future of global banking. If that sounds like you, let’s build what’s next.

About the Team

The Financial Crime Compliance (FCC) team at Airwallex is a strategically vital function operating under a clear Three Lines of Defense model. As the independent second line, FCC owns the global AML/CTF program, sanctions framework, risk assessment methodology, and governance infrastructure across all global entities. As Airwallex scales into new markets and deepens its engagement with global regulatory bodies, we are building a world-class compliance organization capable of managing complex financial crime risks at scale. This is an environment where you will tackle high-impact challenges, shape global fintech risk strategies, and help establish foundations for long-term growth.

The Role

Airwallex is establishing a German 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 Germany.

As Manager, Financial Crime Compliance & the Money Laundering Reporting Officer (“ MLRO ”) for the German 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 German Branch Office operates in accordance with applicable German AML/CTF requirements, BaFin expectations, German Financial Intelligence Unit (“ FIU ”) reporting requirements, applicable EU AML/CTF and sanctions frameworks, and Airwallex NL’s global and regional FCC standards.

You will act as the local FCC lead for Airwallex’s German Branch Office, serving as a key point of contact for BaFin, the German FIU, law enforcement agencies and other relevant German 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 German market.

Key Responsibilities

Regulatory Leadership & BaFin Liaison

• Serve as the designated MLRO for the Airwallex German Branch, fulfilling local AML/CTF obligations under the GwG, as applicable to a branch of a DNB-supervised institution operating in Germany.

• Act as the primary local contact for BaFin in respect of branch-level supervisory matters, regulatory notifications, and any BaFin correspondence or inspections relating to the German Branch.

• Support the EMEA Regulatory and Compliance team in managing the BaFin branch notification and approval process, and maintain ongoing compliance with any conditions or requirements attached to branch authorisation.

Local Compliance Oversight

• Maintain ongoing FCC oversight of the German 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 Germany-based sales, marketing and account management activity, ensuring that commercial activity is appropriately controlled and consistent with the German Branch Office model.

• Ensure that German-specific AML/CTF and sanctions requirements are appropriately reflected in local policies, procedures, escalation routes, training, governance and reporting.

Suspicious Activity Reporting and FIU Engagement

• Oversee local processes for identifying, escalating, assessing and, where required, reporting suspicious activity to the German FIU in accordance with applicable German requirements.

• Work closely with the EMEA FCC team to ensure that Germany-related suspicious activity is identified, investigated, escalated and documented appropriately.

• Provide MLRO review and decision-making input on Germany-related suspicious activity, customer exits, account restrictions, law enforcement requests and other financial crime risk outcomes where local German input is required.

Commercial Enablement & Risk Advisory

• Serve as the embedded compliance partner for the German commercial and sales team, providing day-to-day regulatory guidance on customer queries, product use cases, and market-specific risk scenarios.

• Advise on German 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 German market, ensuring controls are proportionate and consistent with BaFin 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.

• Fulfil any local reporting obligations to BaFin arising from the branch's regulatory status, in coordination with Airwallex NL's Compliance and Legal teams.

Audit & Remediation

• Support the response to BaFin 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.

Who You Are

Minimum Qualifications

• Education: Bachelor's Degree in Law, Finance, Business, or a related field is preferred.

• Experience: 5+ years of experience in financial crime compliance with experience as an MLRO within a regulated financial institution, payment institution, or Fintech operating in Germany or the broader EU/EEA market.

• Regulatory Knowledge: Sound knowledge of German AML/CTF obligations under the Geldwäschegesetz (GwG), the role of BaFin in supervising branch-level activity, and the FIU's Verdachtsmeldung framework; familiarity with how EU AML Directives (AMLD5/AMLD6) are applied in Germany.

• Regulatory Exposure: Prior experience interacting with BaFin and/or the FIU, whether in a direct or supporting capacity (e.g., branch notifications, regulatory correspondence, supervisory examinations).

• Operational Judgement: Demonstrated ability to manage suspicious activity escalations, STR/Verdachtsmeldung filings via goAML, and to make sound, timely compliance decisions in a fast-paced commercial environment.

• Stakeholder Management: Ability to credibly engage internal stakeholders across compliance, legal, and commercial functions, and to represent Airwallex professionally before German regulatory authorities.

• Language: Business-level proficiency in both German and English is required; the ability to conduct regulatory correspondence and draft compliance documentation in German is essential.

Preferred Qualifications

• Experience supporting a branch office or cross-border operation of a foreign-licensed financial institution or e-money institution in Germany, with an understanding of the DNB/BaFin supervisory interface.

• Experience in payments, fintech, or e-commerce, supporting cross-border products, card issuing/acquiring, or embedded finance use cases in the German 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 German commercial context.

• Familiarity with BaFin's Auslegungs- und Anwendungshinweise zum GwG 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.