CDD Risk and Controls Officer
- Hiring from
- Netherlands, Poland, Spain
- Work type
- Remote
- Posted
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External: CDD Risk and Controls Officer
Internal: CDD Subject Matter Expert (2LOD)
The Role
Finom Payments serves small and medium-sized businesses across Europe, and every new customer passes through our CDD controls at onboarding. As CDD SME in the Second Line of Defence, you find where those controls are being bypassed, turn what you find into detection logic, and prove that the new controls work.
You work side by side with the CDD Risk Manager, who owns the effectiveness of the CDD Risk Engine. You supply the investigative insight and evidence. Together you decide which controls to change, and you measure the result.
What You Will Own
You are accountable, together with the CDD Risk Manager, for three outcomes:
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Decline rate: declining the right applicants, not only more of them.
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Gross fraud rate: reducing losses from fraud that gets through onboarding.
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Early forced closures: reducing accounts we have to close shortly after opening because the risk should have been caught earlier.
Responsibilities
Detect
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Analyse external sources (police, partners, industry typology reports) and internal sources (anomaly reports, model outputs) to find anomalies in the CDD profiles of Finom customers.
Build and monitor
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Turn each confirmed anomaly into a documented FinCrime scenario and add it to Finom's FinCrime Scenarios Library, covering the full range of AML risks.
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Work with the CDD Risk Manager to design mitigation measures for each scenario.
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Draft and review system requirements with Product and Engineering for new financial crime features.
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Test, launch and monitor the performance of CDD controls at account opening. For each control, report its effect on decline rate, fraud rate and customer friction.
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Support improvements to the Ongoing and Regular Review processes.
Enable the organisation
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Develop training materials for the CDD and Quality Assurance teams, based on real cases and current scenarios.
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Identify and drive process improvements within the department.
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Initiate and own ad hoc projects within the department.
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Take on other duties reasonably required for Finom's operational efficiency, whether you identify them or your manager assigns them.
Desired Experience and Skills
Required
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3+ years in the Second Line of Defence at a regulated financial institution, (preferably a fintech or neobank or payment institution) serving SMEs with a focus on CDD
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Thorough knowledge of AML regulation and of money laundering and fraud typologies, such as mule accounts, shell companies, beneficial ownership obfuscation, and document and identity fraud.
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Hands-on use of analytical tools such as Power BI, Metabase and Databricks to find patterns in customer and transaction data.
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Structured, evidence-based thinking: you form a hypothesis, test it on data, and state your conclusion and its limits.
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Attention to detail, and the ability to work on your own initiative with little supervision in a fast-moving start-up environment.
Strong plus
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SQL, used to query data yourself rather than waiting for an analyst.
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Practical use of AI tools in investigation, research or analysis.
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Experience tuning rules or thresholds and measuring false positives.
How You Work
Finom rejects the "Compliance says no" mentality. We want a colleague who empowers the business instead of limiting it: someone who weighs risk against customer impact, challenges the status quo, and proposes alternatives to a flat refusal.
You communicate with colleagues at every level of seniority. You present your findings and recommendations in plain, concise language to people who are not compliance specialists, such as Product, Engineering and Operations.
