MLRO / Hvidvaskansvarlig & Head of FCP

up to 75,000 DKK gross/month (depending on seniority level)

We are looking for an experienced financial-crime leader to be our registered MLRO / Hvidvaskansvarlig (HVL § 7, stk. 2) for Monta Pay ApS under our EMI license and to lead Financial Crime Prevention (FCP) across Monta, group-wide for the Danish/EEA EMI plus UK and US compliance as those markets scale. The role is registered with Finanstilsynet, so the appointment is subject to a fit & proper assessment as a change of key function holder.

Monta Pay ApS holds an Electronic Money Institution (EMI) license, granted by Finanstilsynet in April 2026. We are now migrating our financial services from Monta ApS to Monta Pay ApS, with go-live planned for Q2 2027. This is the moment the AML/FCP framework moves from build to live operation, and you will own it.

This is a high‑profile, senior role. You sit at the centre of our financial‑services compliance strategy as we scale, "directly exposed to the fire." You must balance obligations against resources with a risk‑based approach, communicate complex issues clearly to senior leaders and the Board, and run your work‑streams with strong, solution‑oriented project management. In return, you have an outsized impact on how Monta builds and operates financial services compliance, and direct exposure to decision‑making at a fast‑growing scale‑up.

You report day to day to Nick Skovsen, COO of Monta Pay ApS, with direct, independent access to the CEO and executive management of Monta Pay ApS and to its Board and Governance, Risk & Compliance Committee.

Key responsibilities

• Registered MLRO / Hvidvaskansvarlig: Act as the statutory AML‑responsible person for Monta Pay under the EMI license. Approve AML/CTF policies and high‑risk customer relationships escalated by the first line (PEPs, and business involving high‑risk third countries). Receive internal escalations, decide on and file SARs/STRs with the FIU, and be the primary AML contact for Finanstilsynet.

• Own the Financial Crime Prevention framework: Steward Monta's FCP model (our nine‑pillar "FC9" framework) covering AML/CFT, sanctions, fraud, and anti‑bribery & corruption. Propose the risk appetite and risk‑based approach for Board approval and monitor against it, and keep the framework effective and proportionate to our activities, customer types (B2B & B2C), and transaction flows.

• Fraud, transaction monitoring & customer due diligence: Own the frameworks for fraud prevention, transaction monitoring, and KYC/KYB (CDD/EDD, PEP and sanctions screening) across onboarding and the lifecycle (EU and US). Set the rules, thresholds and procedures the Financial Operations team runs in the first line, and assure their quality and effectiveness.

• Sanctions & screening: Set the screening standards (lists, thresholds, re‑screening frequency) and assure the quality of first‑line alert handling.

• Policy suite, risk assessment & governance: Maintain the AML/CFT policy suite in the Centralised Policy Register (with version control and Board‑approval tracking), and own the Business‑Wide Risk Assessment (BWRA) and the AML risk assessment underpinning the framework.

• Regulatory reporting: Deliver AML and payments regulatory reporting (for example Section 99 Payment Act, KPSD, AML/CTF returns) and ensure CESOP readiness.

• Technology, controls & assurance: Work with Product and Engineering on case management, screening and monitoring tooling and AI/automation, oversee AML‑relevant third parties, and run the internal‑controls framework (monitoring, QA, remediation).

• Training, culture & Board liaison: Build AML/FCP training and a strong compliance culture, and advise Senior Management and the Board GRC Committee on financial‑crime risk, regulatory change, and performance.

• Build and lead the team: Build out and lead the second‑line FCP/AML team as volumes grow post go‑live.

What You’ll Walk Into (first 6 to 12 months)

• The foundations are in place; the job is to make them operational for go‑live.

• On AML: everything required to obtain the EMI license has been submitted and approved. The remaining gap is operational readiness, and that is the focus: embedding the framework in day‑to‑day operations and rolling it out with our customers and with colleagues across Monta.

• Concrete early priorities include standing up transaction monitoring and fraud detection, locking v1.0 of the policy suite (Sanctions, PEP, EDD, Outsourcing, and the Sanction‑Screening and SAR/STR filing SOPs) into the Centralised Policy Register, building the regulatory‑reporting data structure and CESOP readiness, finalising KYC/KYB (EU + US), and securing your Finanstilsynet fit & proper approval ahead of g