Head of Compliance & MLRO, Kazakhstan

Regulatory Licensing & Engagement

• Lead the preparation and submission of the AFSA licence application including drafting compliance-related sections of the application pack.
• Serve as the primary point of contact with the AFSA and other relevant Kazakhstani regulatory bodies throughout the licensing process and on an ongoing basis.
• Ensure the organisation meets all AIFC governance requirements, including fit and proper obligations for Approved and Designated Persons.
• Monitor and interpret regulatory developments under the Law of the Republic of Kazakhstan "On Digital Assets" (No. 193-VII), AIFC Acts, and associated AFSA rules, and advise the Board accordingly.

Compliance Programme Development & Management

• Design, implement, and maintain a comprehensive compliance framework aligned with AIFC requirements, FATF recommendations, and international best practice for virtual asset service providers (VASPs).
• Develop, review, and update all internal policies and procedures covering AML/CFT, KYC, customer due diligence (CDD), enhanced due diligence (EDD), transaction monitoring, sanctions screening, data protection, cybersecurity compliance, and safeguarding of client assets.
• Establish and oversee the compliance monitoring programme, including periodic testing, gap analysis, and reporting to senior management and the Board.
• Prepare and present regular compliance reports to the Board and relevant committees, including on regulatory changes, compliance breaches, and remediation progress.

AML/CFT & MLRO Duties

• Act as the designated MLRO, with full statutory responsibility for overseeing the organisation's AML/CFT framework in accordance with Kazakhstan Law and AIFC AML rules.
• Receive, review, and assess all internal Suspicious Activity Reports (SARs) from staff, and make informed decisions on whether to file external disclosures with Kazakhstan's Financial Intelligence Unit (FIU) and other competent authorities.
• Oversee and continuously improve the transaction monitoring programme, with support from global compliance and product functions.
• Ensure robust sanctions screening against all applicable lists, including OFAC, UK OFSI, UN, EU, and domestic Kazakhstan sanctions designations.
• Oversee customer risk scoring, risk-based KYC/CDD processes, and enhanced due diligence for high-risk customers, politically exposed persons (PEPs), and customers from high-risk jurisdictions.

Governance & Culture

• Act as a key member of the senior leadership team, providing compliance input on new products, services, partnerships, and business initiatives.
• Champion a strong compliance culture across the organisation through training, communications, and leadership by example.
• Design and deliver AML/CFT and compliance training programmes for all staff, ensuring completion records are maintained.
• Ensure that the organisation's compliance obligations are adequately resourced, and advise the Board on staffing, systems, and budget requirements.
• Establish and maintain a compliance manual, risk register and oversee the escalation and resolution of compliance incidents and breaches.

Reporting & Recordkeeping

• Prepare and submit all required regulatory reports and notifications to AFSA, the Financial Intelligence Unit, and other authorities within stipulated deadlines.
• Ensure that all compliance records, SAR documentation, KYC files, and transaction monitoring records are maintained in accordance with applicable retention requirements.
• Support and facilitate any AFSA inspections, supervisory visits, or regulatory examinations.

Qualifications

• Bachelor's degree in Law, Finance, Business, or a related field. A postgraduate qualification is advantageous.
• Professional certification in compliance or AML is strongly preferred (e.g. CAMS, ICA Certificate/Diploma in AML or Compliance, CFE, or equivalent).

Experience

• Minimum of 8 years of experience in compliance, AML, or financial crime prevention, with at least 3 years in a senior or leadership compliance role.
• Demonstrated in-house experience working within virtual asset service providers (VASPs), cryptocurrency exchanges, fintech firms, or regulated financial institutions.
• Prior experience as an MLRO or Deputy MLRO is highly desirable.
• Experience engaging directly with financial regulators in Kazakhstan.
• Hands-on experience building compliance programmes from the ground up in a start-up or scaling environment is a significant advantage.
• Familiarity with the AIFC regulatory framework and AFSA requirements is strongly preferred.

Knowledge & Skills

• Deep understanding of FATF Recommendations and their application to virtual asset service providers, including the Travel Rule.
• Strong knowledge of crypto-specific AML typologies.
• Proficiency with blockchain analytics and transaction monitoring tools (e.g. Chainalysis, Elliptic, TRM Labs, or equivalent).
• Excellent written and verbal communication skills in English and Kazakh. Proficiency in Russian is a significant advantage given the regulatory environment and the typologies relevant to the role.
• Strong analytical and investigative skills, with the ability to identify and articulate complex risk scenarios clearly.
• Demonstrated ability to engage constructively with regulators, external auditors, and law enforcement.
• High degree of personal integrity and sound professional judgment.

• Experience in cryptocurrency or blockchain compliance programs.
• Familiarity with compliance technology and analytics tools.
• Prior exposure to multi-jurisdictional compliance oversight.