MLRO

Money Laundering Reporting Officer (MLRO) and Acting Head of Compliance Job Description

ClearToken Depository Limited

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 MLRO role. There is no direct UK peer for the Firm's market infrastructure model in digital assets. The MLRO and Acting Head of Compliance has the opportunity to define the financial crime framework from first principles, building it as an automation-first, data-driven function that scales with the business, and applying controls proportionately to actual residual risk. The role transforms a building-stage function into the second line for live, scaled UK digital asset market infrastructure.

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). The Firm intends to make two further submissions to the FCA:

• Part 4A authorisation under FSMA 2000 as an investment firm; and
• Once Part 4A authorisation is in force,asa Variation of Permission (VoP) to add the new FSMA 2023cryptoassetregulated activities, includingcustody, arranging,andsafeguardingof qualifyingcryptoassetsunder Article 9O of the Regulated Activities Order.

The most significant feature of this role is the breadth and continued expansion of regulatory domains it spans, from payments and cryptoasset registration into investment firm activities, custody of specified investments and the FCA's Client Assets Sourcebook (CASS) regime, alongside the new safeguarding regime for qualifying cryptoassets.

This approach has already delivered tangible regulatory progress: following sustained investment in its controls, the FCA has lifted two of the Directions applying to the Firm and modified a third. This role is expected to sustain this trajectory, keeping the control environment strong and credible.

The role is offered as MLRO and Acting Head of Compliance, with the post-holder discharging the Head of Compliance responsibilities on an interim basis. As the Firm's regulatory perimeter expands, the Group intends to establish a dedicated Group Head of Compliance and separate the regulatory compliance responsibilities from the MLRO and financial crime function, enabling a future split of Compliance Oversight (anticipated SMF16) from the MLRO function (anticipated SMF17).

We are looking for a financial crime and compliance leader with expertise across these domains, with depth in the FSMA, MiFID and banking environment and the cryptoasset landscape. Cryptoasset and blockchain specialism will be further provided by a dedicated Deputy MLRO (DMLRO), reporting to this role.

The remit is broad by design. We value a growth mindset and readiness to develop across these domains above a perfect match to every requirement, and we encourage candidates with strong core expertise to apply.

Reporting Line

The MLRO and Acting Head of Compliance of ClearToken Depository Limited reports directly to the CEO of ClearToken Depository Limited.

The role also has a functional reporting line to the Group Chief Risk Officer, who runs the Group's second line of defence, and it operates within the broader Group governance framework as part of a subsidiary of ClearToken UK Holdings Limited. The MLRO reports regularly to the Board of ClearToken Depository Limited and to the Board Risk and Audit Committee, with direct, unfettered access to both on financial crime, AML and sanctions matters.

The role serves as a member of the Depository's Executive Committee, the Executive Risk and Compliance Committee, and the New Participant (AML) Committee.

Responsibilities and Duties

Core Responsibilities

• Define the Firm's financial crime framework tailored to its UK market infrastructure model; shape framework design from first principles and engage constructively with the FCA, OFSI and the National Crime Agency on how the Firm's controls and processes are calibrated to the Firm's risk profile and operating model;
• Sustain and build on the Firm's regulatorytrack record,maintainingarobustcontrol environment, and evidencing the ongoing effectiveness of the framework to the Board and the FCA;
• Lead and scale the second line Compliance and Financial Crime function, designing and operating a scalable, automation-first, data-driven control environment for the Firm's evolution from early-stage to high-velocity market infrastructure, and applying commercial, proportionate, risk-based judgment that differentiates genuine residual risk from noise while sustaining a defensible framework calibrated to actual residual risk and regulatory obligations;
• Partner with the Group Regulatory Engagement function on the Firm's two forthcoming FCAsubmissions(Part 4A FSMA 2000 authorisation and the subsequent FSMA 2023cryptoassetVariation of Permission); build out the second line systems, controls and governance required across the materially broader regulatory perimeter, including investment firm activities, custody of specified investments, SM&CR, CASS and the new CRYPTO sourcebook; hold such Senior Management Functions and Prescribed Responsibilities as the Firm's Board allocates;
• Act as the Firm's nominated officer, with personal accountability for the Firm's compliance with UK AML, counter terrorist financing (CTF), counter proliferation financing (CPF), sanctions and broader financial crime obligations, including the decision to file external Suspicious Activity Reports with the National Crime Agency (including DAML where relevant), reports to the Office of Financial Sanctions Implementation (OFSI) and notifications to the FCA;
• Direct and develop the Compliance and Financial Crime team, including the DMLRO, AML operations and second line analytics, ensuring adequate succession and resilience for the nominated officer function, and foster a culture of compliance, sound judgment, ethics and proportionate challenge across the Depository and the Group;
• Submit the annual MLRO Report to the Board and the Board Risk and Audit Committee on the operation and effectiveness of the AML, CTF, CPF and sanctions framework, in line withFCA SYSC 6.3.7G, and provide regular Financial Crime Management Information to the Executive Risk and Compliance Committee and the Board Risk and Audit Committee, escalating material financial crime risks to the Board.

Compliance and Financial Crime Leadership

• Own theFirm's financial crime risk assessment, transitioning from a standalone Business Wide Risk Assessment (BWRA) into the financial crime module of theClearTokenGroup Enterprise Risk Management Framework (ERMF) while maintaining the underlying MLR 2017 obligations throughout; refresh annually and on event-driven triggers; present to the Board for review and approval; ensure findings inform the design and calibration of the Firm's financial crime controls;
• Own the Firm's Financial Crime Framework and the Firm's AML, sanctions, transaction monitoring and wallet screening policies and procedures, ensuring allremainup to date and fit for purpose against evolvingcryptoassettypologies and regulatory expectations;
• Own the Firm's 5MLD Equivalence assessment framework, including determination ofjurisdictionscategorised as 5MLD-equivalent and the underlyingmethodology;
• Maintain the Client Risk Assessment Tool, the Client Risk Scoring Methodology and related second line standards; provide second line oversight of Customer Due Diligence and Enhanced Due Diligence; determine the EDD measures applicable to high-risk prospective Participants; endorse cases before submission to the New Participant (AML) Committee for approval;
• Provide strategic oversight of the Firm's rules-based, data-driven sanctions and wallet screening framework (rules engine, quantitative data pack, action-class routing); set, calibrate and approve detection thresholds and the ruleset (for examplehop count, recency, materiality,andjurisdiction risk weighting);
• Authorise enhanced review escalations, freezes, wallet quarantine, walletdeactivationand post-resolution reactivation per the decision authority matrix; apply judgment to residual cases outside the standard rules-based path under the Firm's exceptions framework, owning the evidential record for those determinations;
• Define and own the Firm's annual financial crime training plan, including role-specific training for staff with AML, CTF, CPF or sanctions accountability and for those engaging with higher-risk situations; ensure the Board and Executive Management receive appropriately tailored training at least annually;
• Act as Head of Complianceon an interim basis, owning the Firm's regulatory compliance framework across its full perimeter, andadvisingthe business on its regulatory and conduct obligations;
• Own a firmwide Compliance Monitoring Plan covering all regulatory obligations and report its outcomes to the Board Risk and Audit Committee;
• Lead regulatory horizon scanning and change management, assessing new and amended requirements and directing their implementation across policies,proceduresand controls;and

• Oversee regulatory reporting and returns, complaints handling and the Firm's compliance relationship with the FCA beyond financial crime matters.

Day-to-day

• Engage regularly with the CEO ofClearTokenDepository Limited and the Group Chief Risk Officer to ensure effective coordination of second line oversight and alignment on operational priorities;
• Act as the Firm's principal point of contact with the FCA, OFSI and the National Crime Agency on financial crime, AML and sanctions matters; oversee the Firm's response to regulatory queries, periodic returns (including REP-CRIM), audits, thematicreviewsand supervisory engagements;
• Maintain relationships with key external advisers and assurance providers, including the BWRA assurance provider, blockchain analyticsprovidersand external training specialists;facilitateindependent audits and reviews of the AML and financial crime framework and own the remediation of findings;
• Review the outputs of the rules engine and the quantitative analytics on a periodic basis as part of the Compliance Monitoring Plan; assure ongoing effectiveness and challenge rule calibration whereindicated;
• Develop the MLRO Report, Financial Crime Management Information and second line assurance outputs on the cadence required by the Compliance Monitoring Plan and Board reporting calendar;and
• Track and close commitments arising from the MLRO Report, FCA remedial and enhancement actions, and external assurance findings, providing evidence of closure to the Board and the Board Risk and Audit Committee.

Qualifications and Skills

• Senior-level experience in financial crime, including prior accountability as a UK MLRO, nominated officer or equivalent, with a track record of building, not just operating, financial crime functions at scale: framework design and embedding, automation and analytics deployment, and team development through scale-up;
• Strong commercial judgment, with the ability to differentiate genuine residual risk from noise, calibrate controls proportionately, and balance regulatory expectations with operational realities;
• Excellent communication,negotiationand stakeholder management skills, with the ability to influence at all levels and across cultures, including with executive peers, theBoardand external authorities;
• High ethical standards, integrity, and accountability, with a commitment to the Depository's and Group's vision and values;
• Track record of constructive, credible engagement with the FCA and other competent authorities, on financial crime framework design and calibration of controls beyond compliance with prescribed obligations as well as on periodic returns, queries, supervisory engagement and the preparation and submission of Suspicious Activity Reports (including SARs involvingcryptoassets) and OFSI reports;
• Experienceoperatingin or alongside financial market infrastructure (central counterparties, central securities depositories, paymentsystemsor analogous regulated environments);
• Substantive experience of the FSMA and UK MiFID investment firm regime and of banking or comparable regulated financial services, with the depth to lead across investment firm activities, custody and client assets and to operate across multiple FCA and Bank of England regulatory regimes; substantive working knowledge of, or credible readiness to develop, the FCA Part 4A authorisation regime for investment firms, SM&CR and CASS;
• Substantive knowledge of, or credible readiness to develop, custody and client asset arrangements for specified investments and qualifyingcryptoassets, including segregation, trust structures, reconciliations, third-party custody oversight, the proposed CASS chaptersfor custody andsafeguarding of qualifyingcryptoassets,and Article9Osafeguarding;
• Sound working knowledge ofcryptoassetfinancialcrimeriskinblockchainandsimilarly regulated digital asset environments, includingcryptoassettypologies, the UKcryptoassetregistration regime, the Travel Rule and VASP-to-VASP data exchange standards, and developments in the emerging UKcryptoassetregulatory regime;
• 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 to design,calibrateand oversee a rules-based, data-driven financial crime framework, and to direct (not perform) quantitative and analytics capability;able tointerpret blockchain analytics outputs at a strategic leveland to direct the specialist capability held by theDMLRO;and

• Ability toidentifyand evaluate opportunities toleverageAI and emerging technologies to enhance financial crime detection, investigation and analytics, balanced with responsible adoption.

Location and Commitment

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

Regulatory Context

On grant of Part 4A FSMA 2000 authorisation as an investment firm, the Firm will 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 (VoP) 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. The MLRO and Acting Head of Compliance will be subject to SM&CR, anticipated to hold SMF17 (Money Laundering Reporting Officer) and such other Senior Management Functions and Prescribed Responsibilities as the FCA approves and the Board allocates; allocation of SMF16 (Compliance Oversight) and operational oversight responsibility for CASS will be determined by the Board, having regard to capacity, independence and skill.

The role-holder is subject to fit and proper requirements under the Money Laundering Regulations 2017 (in respect of the Firm's cryptoasset registration) and, on Part 4A authorisation, under SM&CR.