Manager, ERCS, MLRO in Sydney at PayPal

Date Posted: 5/1/2018

Job Snapshot

Job Description

Fueled by a fundamental belief that having access to financial services creates opportunity, PayPal (NASDAQ: PYPL) is committed to democratizing financial services and empowering people and businesses to join and thrive in the global economy. Our open digital payments platform gives PayPal’s 237 million active account holders the confidence to connect and transact in new and powerful ways, whether they are online, on a mobile device, in an app, or in person. Through a combination of technological innovation and strategic partnerships, PayPal creates better ways to manage and move money, and offers choice and flexibility when sending payments, paying or getting paid. Available in more than 200 markets around the world, the PayPal platform, including Braintree, Venmo and Xoom enables consumers and merchants to receive money in more than 100 currencies, withdraw funds in 56 currencies and hold balances in their PayPal accounts in 25 currencies.

The key primary responsibilities are maintaining appropriate local processes, policies and procedures to ensure compliance with relevant laws, prudential standards, rules and guidelines and codes of practice throughout Australian operations with a focus on the AML/CTF Act.

  • To lead in the facilitation and implementation of the financial crime (i.e. anti-money laundering, combating terrorist financing, sanctions, anti-fraud, and anti-bribery and corruption) programme across all relevant parts of the PayPal Australia and liaise with outsourced functions to monitor compliance.
  • To participate in the Global AML/CTF Risk Assessment process and conduct a local financial crime risk assessment incorporating conclusions into local policies as required.
  • Leading an annual review/update to the Prevention of Anti Money laundering and Terrorist Financing Programme (AML/CTF Programme) including sign off by the Board.
  • To agree remediation plans with management for all incidences of non-compliance with policy/procedure and follow up implementation on a timely basis, escalating as necessary.
  • To make practical and acceptable recommendations where systems and procedures need enhancing to counter the risk of financial crime.
  • To notify the Board through timely reporting of all incidences of non-compliance with regulation and legislation. All breaches to also be notified to Chief Risk Officer.
  • To prepare regular reports on the outputs of the monitoring programme to the Executive summarising key issues, results, conclusions and actions taken.
  • To produce an annual MLRO report for the Board.
  • To review suspicious activity reports, Politically Exposed Person escalations and other relevant cases where needed and ensure appropriate SMRs are lodged to Austrac.
  • Ensure Enhanced Due Diligence is completed for higher risk transactions and client relationships (at on-boarding and periodic review) in line with policy requirements. To escalate exceptional transactions or relationships to the relevant parties.
  • To ensure the effective operation and monitoring of outsourced customer and transaction screening services, including involvement in projects connected to the management and maintenance of outsourced services and service providers.
  • To monitor outsourced regulatory reporting responsibilities in respect of financial crime.
  • To co-ordinate the fulfilment of ad hoc Orders received from regulatory or law enforcement agencies in a timely manner as required.
  • To prepare and maintain PayPal Australia’s Country Risk Profile assessing potential territorial exposures to money laundering and terrorist financing for input into the Global Risk Profile.
  • To ensure that the PayPal Australia remains up to date with relevant regulatory developments and ensures these are communicated to PayPal Group for inclusion in Group Policies as needed.
  • To advise on the development and maintenance of, and sign-off where appropriate, of financial crime compliance procedures.
  • To respond promptly to requests for advice or information from PayPal Australia senior management, the external auditors or the regulatory or law enforcement bodies.
  • To develop and maintain excellent working relationships with client facing departments.
  • To manage the development and delivery of financial crime training courses to PayPal Australia management and staff where needed. 
  • To conduct an annual assessment of training needs and a review and update of core intranet based training material relevant to the local business.


  • Maintain an understanding of the requirements of Australian legislation and other relevant regulations and guidance relating to financial crime.
  • To maintain understanding and expertise in wider Financial Crime Compliance Regulation and guidance from relevant bodies.
  • To maintain understanding of jurisdictional risk relating to financial crime.

We're a purpose-driven company whose beliefs are the foundation for how we conduct business every day. We hold ourselves to our One Team Behaviors which demand that we hold the highest ethical standards, to empower an open and diverse workplace, and strive to treat everyone who is touched by our business with dignity and respect. Our employees challenge the status quo, ask questions, and find solutions. We want to break down barriers to financial empowerment. Join us as we change the way the world defines financial freedom.

PayPal provides equal employment opportunity (EEO) to all persons regardless of age, color, national origin, citizenship status, physical or mental disability, race, religion, creed, gender, sex, pregnancy, sexual orientation, gender identity and/or expression, genetic information, marital status, status with regard to public assistance, veteran status, or any other characteristic protected by federal, state or local law. In addition, PayPal will provide reasonable accommodations for qualified individuals with disabilities.



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