Deputy MLRO

Summary ClearToken is building UK regulated market infrastructure for digital assets. The Group's vision is to bring traditional market infrastructure principles (transparency, efficiency and settlement finality) to the institutional digital asset ecosystem through the regulated depository product suite operated by ClearToken Depository Limited (‘the Firm’).

This is not a standard deputy role. ClearToken is an early-stage firm building its financial crime function from a clean sheet, without the legacy systems and entrenched processes that constrain established institutions. The Deputy Money Laundering Reporting Officer (DMLRO) is the operational core of that function, an automation-first, data-driven capability designed from first principles, with genuine scope to shape how it is built and how AI and emerging technologies are deployed to detect, investigate and analyse financial crime. Sitting where blockchain analytics, sanctions and wallet screening, and transaction monitoring meet, the role-holder turns the Firm's systems into decisions. The role is weighted towards cryptoasset and digital asset expertise, ownership of screening processes and financial crime data analytics.

The Firm is authorised by the Financial Conduct Authority (FCA) as an Authorised Payment Institution under the Payment Services Regulations (PSRs) 2017 (FRN 1017352) and registered with the FCA under the Money Laundering Regulations (MLRs) 2017 as a cryptoasset business (FRN 1016940). It intends to broaden this regulatory perimeter through further FCA submissions.

We are looking for a financial crime practitioner with deep, hands-on expertise in cryptoasset typologies, blockchain analytics and screening operations.

Reporting Line

The DMLRO reports to the MLRO and Head of Compliance of ClearToken Depository Limited, within the Firm's second line Compliance and Financial Crime function.

The role deputises for the MLRO and Head of Compliance and operates within the broader Group governance framework as part of a subsidiary of ClearToken UK Holdings Limited.

Responsibilities and Duties

Core Responsibilities

• Run the Firm's financial crime control environment day to day and drive its continuous improvement, shaping and calibrating an automation-first, data-driven framework proportionate to actual residual risk;
• Where designated as Deputy MLRO to act in the MLRO's absence, exercise the MLRO (nominated officer)functionaccordingly, including decisions to escalateand file Suspicious Activity Reports (including Defence Against Money Laundering requests) with the National Crime Agency, reports to the Office of Financial Sanctions Implementation (OFSI), and urgent sanctions determinations;
• Keep the Firm's Financial Crime Framework, Compliance Monitoring Plan and AML, sanctions and related policies and procedures current and effective against evolvingcryptoassettypologies and regulatory expectations, safeguarding the Firm's compliance with its UK AML, counter terrorist financing (CTF), counter proliferation financing (CPF)and sanctions obligations;
• Produce the second line analytics and assurance that underpin the Firm's Financial Crime Management Information, the annual MLRO Report and regulatory returns;
• Build out the second line controlsrequiredas the regulatory perimeter expands across investment firm activities, custody,SM&CRand CASS.

Crypto and Digital Asset Screening

• Own the day-to-day operation of the Firm's rules-based, data-driven sanctions and wallet screening framework (rules engine, quantitative data pack, action-class routing); monitor detection performance and calibrate the ruleset (for example,hop count, recency, materiality,andjurisdiction risk weighting);
• Triage,validateand investigate alerts from the Firm's trade surveillance, transaction monitoring, transactionscreeningand wallet screening systems,assessingrisk signalssuch aswallet exposure,clustering, transaction paths, mixer interactions,andsanctioned-address connections;
• Conduct in-depth blockchain investigations using blockchain analytics tooling; prepare investigation files and make or escalate decisions on cases, including enhanced review escalations, freezes, wallet quarantine, walletdeactivationand post-resolution reactivation, within the Firm's decision authority matrix;
• Review and challenge Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD) on onboarding and ongoing monitoring, and present cases to the New Participant (AML) Committee;
• Apply andmaintainthe Firm's 5MLD Equivalence AssessmentMethodology, andoversee compliance with the Firm’s Travel Rule Compliance Policy.

Financial Crime Analytics and Automation

• Build, run and interpret the quantitative analytics that underpin the screening and monitoring framework; interrogate complex data sets, tune rules to reduce false positives without eroding true-positive capture, and evidence detection effectiveness;
• Develop andmaintainthe data pack, metrics and dashboards that support the Compliance Monitoring Plan, effectivenessassuranceand Board reporting;
• Lead the adoption of AI and emerging technologies across financial crime detection,investigationand analytics, building on the Firm's existing AI tooling, with responsible adoption and clear auditability;
• Maintain clear auditability and documentation for all financial crime decisions and for changes to rules,thresholdsand models.

Day-to-day

• Partner with the financial crime operations team as the subject matter expert oncryptoassetrisk, guiding their use of the wallet screening and transaction monitoring systems;
• Handle engagement with the FCA, OFSI and the National Crime Agency alongside the MLRO, preparing responses to regulatory queries, periodic returns,auditsand thematic reviews;
• Coordinate internal audits andthird partyassurance reviews of the Firm's crypto-specific financial crime controls, and drive remediation of findings;
• Develop and deliver AML, CTF, CPF and sanctions training as a subject matter expert on financial crime typologies and digital asset risk models;
• Investigate potential suspicious activity and prepare SARs (including SARs involvingcryptoassets), which the MLRO reviews andsubmitsas nominated officer.

Qualifications and Skills

• Substantive, hands-on experience in financial crime withincryptoasset, blockchain, fintech, e-money,paymentsor similarly regulated environments;
• Deep working knowledge of the UK AML, CTF, CPF and sanctions regulatory framework, including the MLRs 2017, the Proceeds of Crime Act, SAMLA2018and OFSI guidance, JMLSG and FATF guidance, and the FCA Financial Crime Guide;

• Demonstrated ability tooperateand calibrate a rules-based, data-driven financial crime framework: alert triage, rule and threshold tuning, false-positivereductionand effectiveness assurance;
• Strong, practical blockchain analytics capability, with fluency interpreting outputs from tools such as Elliptic, Chainalysis and TRM Labs, and the ability to conduct end-to-end blockchain investigations;
• Credible exposure tocryptoassettypologies, the UKcryptoassetregistration regime, the Travel Rule and VASP-to-VASP data exchange standards, and developments in the emerging UKcryptoassetregulatory regime;
• Strong quantitative and analytical capability, comfortable interrogating complex datasetsand typology-based red flags, with the ability to turn data into calibration and assurance decisions;
• Experience preparing andsubmittingSARs, ideally including SARs involvingcryptoassets, and interfacing with regulators;
• Excellent written communication for drafting investigations,reportsand regulatory communications; ability to work independently, exercise sound risk-based judgment, and handle confidential information with discretion;
• Professional certification, for example an ICA Diploma or Advanced Certificate in AML or financial crime, ACAMS or equivalent, andfamiliarity with fraud risk management, sanctions screening tooling and KYC operations is an advantage;
• High ethical standards,integrityand accountability, with commitment to the Depository's and Group's vision and values; proactive and methodical, comfortable managing multiple priorities and challenging stakeholders constructively.

Location and Commitment

London, on-site/hybrid. Full-time.

Regulatory Context

The Firm is currently subject to the Money Laundering Regulations 2017 (in respect of its cryptoasset registration) and the Payment Services Regulations 2017. On grant of Part 4A FSMA 2000 authorisation as an investment firm, the Firm will additionally be subject to the Senior Managers and Certification Regime (SM&CR) and the FCA's Client Assets Sourcebook (CASS); on grant of the subsequent Variation of Permission for the new FSMA 2023 cryptoasset regulated activities (including safeguarding of qualifying cryptoassets under Article 9O of the Regulated Activities Order), the Firm will also be subject to the new CRYPTO sourcebook and the FCA's bespoke CASS chapters.

In the MLRO's absence, the Deputy MLRO acts in the MLRO's place, including exercising the nominated officer function; otherwise the role supports the MLRO and Head of Compliance. The role-holder is subject to fit and proper standards under the Money Laundering Regulations 2017, in respect of the Firm's cryptoasset registration, and to the Firm's own recruitment and ongoing competence requirements.