Deputy MLRO

As Deputy Money Laundering Reporting Officer (DMLRO) at ClearToken, you will build and run the Firm's financial crime function from first principles. ClearToken is a UK-regulated market infrastructure provider for digital assets, authorised by the FCA as an Authorised Payment Institution and registered as a cryptoasset business. This is not a standard deputy role: you have genuine scope to shape how the function is built, how automation and data-driven processes operate, and how AI and emerging technologies are deployed to detect, investigate and analyse financial crime. You sit at the intersection of blockchain analytics, sanctions screening, wallet screening and transaction monitoring, turning the Firm's systems into decisions.

What you'll do

• 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
• Act as Deputy MLRO in the MLRO's absence, exercising the nominated officer function including decisions to escalate and file Suspicious Activity Reports 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 evolving cryptoasset typologies and regulatory expectations, safeguarding compliance with 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 controls required as the regulatory perimeter expands across investment firm activities, custody, SM&CR and CASS
• 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, and jurisdiction risk weighting)
• Triage, validate and investigate alerts from the Firm's trade surveillance, transaction monitoring, transaction screening and wallet screening systems, assessing risk signals such as wallet exposure, clustering, transaction paths, mixer interactions, and sanctioned-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, wallet deactivation and 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 and maintain the Firm's 5MLD Equivalence Assessment Methodology, and oversee compliance with the Firm's Travel Rule Compliance Policy
• 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 and maintain the data pack, metrics and dashboards that support the Compliance Monitoring Plan, effectiveness assurance and Board reporting
• Lead the adoption of AI and emerging technologies across financial crime detection, investigation and 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, thresholds and models
• Partner with the financial crime operations team as the subject matter expert on cryptoasset risk, 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, audits and thematic reviews
• Coordinate internal audits and third party assurance 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 involving cryptoassets), which the MLRO reviews and submits as nominated officer

What you bring

• Substantive, hands-on experience in financial crime within cryptoasset, blockchain, fintech, e-money, payments or 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, SAMLA 2018 and OFSI guidance, JMLSG and FATF guidance, and the FCA Financial Crime Guide
• Demonstrated ability to operate and calibrate a rules-based, data-driven financial crime framework: alert triage, rule and threshold tuning, false-positive reduction and 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 to cryptoasset typologies, the UK cryptoasset registration regime, the Travel Rule and VASP-to-VASP data exchange standards, and developments in the emerging UK cryptoasset regulatory regime
• Strong quantitative and analytical capability, comfortable interrogating complex data sets and typology-based red flags, with the ability to turn data into calibration and assurance decisions
• Experience preparing and submitting SARs, ideally including SARs involving cryptoassets, and interfacing with regulators
• Excellent written communication for drafting investigations, reports and regulatory communications; ability to work independently, exercise sound risk-based judgment, and handle confidential information with discretion
• High ethical standards, integrity and accountability, with commitment to the Depository's and Group's vision and values; proactive and methodical, comfortable managing multiple priorities and challenging stakeholders constructively

Nice to have

• Professional certification, for example an ICA Diploma or Advanced Certificate in AML or financial crime, ACAMS or equivalent
• Familiarity with fraud risk management, sanctions screening tooling and KYC operations

What we offer

• Full-time position based in London on-site/hybrid

About ClearToken

ClearToken is building UK regulated market infrastructure for digital assets. The Group operates through ClearToken Depository Limited, an Authorised Payment Institution under the Payment Services Regulations 2017 (FRN 1017352) and a registered cryptoasset business under the Money Laundering Regulations 2017 (FRN 1016940), with plans to broaden its regulatory perimeter through further FCA submissions.