Head of Financial Crime Investigations
- Hiring from
- Luxembourg
- Work type
- Hybrid
- Posted
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ABOUT US:
As a world leading provider of integrated solutions for the alternative investment industry, Alter Domus (meaning “The Other House” in Latin) is proud to be home to 90% of the top 30 asset managers in the private markets, and more than 6,000 professionals across 24 jurisdictions.
With a deep understanding of what it takes to succeed in alternatives, we believe in being different - in what we do, in how we work and most importantly in how we enable and develop our people. Invest yourself in the alternative, and join an organization where you progress on merit, where you can speak openly with whoever you are speaking to, and where you will be supported along whichever path you choose to take.
Find out more about life at Alter Domus at careers.alterdomus.com
This is a senior leadership position that sits at the heart of Alter Domus's financial crime framework, combining overall responsibility for the Group's Financial Crime Investigations function with critical local regulatory mandates in Luxembourg.
As Head of Financial Crime Investigations, you will lead and develop a team of financial crime professionals responsible for managing high-risk KYC escalations, suspected money laundering, fraud and other financial crime matters across the Alter Domus Group. You will set the strategic direction of the investigations function, own the Group's escalation and investigations frameworks, and act as the senior point of contact for external authorities and law enforcement. You will be accountable for ensuring that financial crime risks are identified, escalated and resolved effectively and consistently across all jurisdictions.
You will hold the position of Responsable du Contrôle (RC) for two Luxembourg entities: Alter Domus Fund Services Limited, a fund services provider supervised by the Commission de Surveillance du Secteur Financier (CSSF), and Alter Domus Business Office Services, supervised by the Administration de l'Enregistrement, des Domaines et de la TVA (AED). In both capacities, you will hold ultimate responsibility for ensuring that each entity meets all applicable AML/CFT and regulatory compliance obligations under Luxembourg law.
YOUR RESPONSIBILITIES
The role will report to the Group Head of Financial Crime as well as the local Board of Directors, with direct access to local and AD Group compliance support functions.
Financial Crime Investigations
- Lead, manage and develop the Financial Crime Investigations team, setting clear objectives, fostering a high-performance culture, and ensuring the team is appropriately resourced and skilled to meet the demands of the function
- Own and maintain the Group's financial crime investigations and escalation framework, ensuring it remains fit for purpose, consistent with Group policy, and aligned with evolving regulatory expectations
- Provide senior oversight and final-stage review and point of escalation of high, medium and prohibited risk client and investor KYC and Know Your Asset escalations, making or approving recommendations to the relevant MLROs where required
- Set and maintain standards for the identification, triage and investigation of suspected financial crimes across the Group, ensuring timely and well-documented resolution
- Own and oversee the Group's procedures for the submission of Suspicious Activity Reports (SARs), Suspicious Transaction Reports (STRs) and Sanctions-related reports to external authorities, ensuring quality, consistency and timeliness
- Lead the Group's engagement with external authorities and law enforcement, acting as a senior point of contact for regulatory and investigative bodies and managing all formal responses and information requests
- Own and maintain the framework for obtaining external Enhanced Due Diligence (EDD) in high-risk scenarios, ensuring appropriate standards are applied consistently across the Group
- Provide oversight and guidance on the management of sanctions licensing applications and the establishment of defences to money laundering offences where applicable
- Maintain senior oversight of the investigation and resolution of confirmed screening hits, ensuring cases are managed to conclusion in a timely, risk-based and documented manner
- Own the Group-wide process for the rejection and/or exit of clients and investors, including governance of the relevant registers and escalation to senior management and Boards as appropriate
- Provide oversight of introducer relationships and AML letters, ensuring appropriate due diligence standards are maintained and exceptions are escalated appropriately
- Produce and present management information and KPIs on financial crime investigations activity, providing meaningful insight into trends, volumes and emerging risks
- Drive continuous improvement across the investigations function, identifying and implementing enhancements to processes, tools and controls in response to operational experience and regulatory developments
- Act as the nominated Responsable du Contrôle for both Alter Domus Fund Services Limited (CSSF) and Alter Domus Business Office Services (AED), holding ultimate accountability for the AML/CFT compliance framework of each entity and serving as the primary point of contact with the respective supervisory authority
- Aligned to the Compliance operating model you will ensure that client and investor due diligence is collected and maintained to the appropriate standard and that a robust financial crime monitoring programme is in place and operating effectively, and that both entities remain compliant with all applicable regulatory requirements of their respective supervisors
- Prepare and present compliance and AML/CFT reporting to the Boards of Directors of each entity, providing clear and timely insight into the compliance position of each business
- Ensure all required regulatory reporting to the CSSF and AED respectively is submitted within prescribed deadlines
- Maintain oversight of regulatory publications from both the CSSF and AED, ensuring that new and revised regulations, circulars and guidance are promptly assessed and their implications communicated to the relevant Boards and employees
- Ensure that the financial crime and AML/CFT framework in place adheres to the requirements of the respective supervisory authority at all times
Your Profile
- Significant experience in a financial crime compliance role, ideally within a regulated financial services environment encompassing fund administration, corporate services, trusts or related sector.
- Deep expertise in managing complex financial crime investigations, including SAR/STR filings, engagement with FIUs and law enforcement, and the management of high-risk client escalations
- Strong working knowledge of Luxembourg AML/CFT legislation and regulation, including the Law of 12 November 2004 as amended, CSSF regulations and circulars, and a sound understanding of the AED supervisory framework
- Expert knowledge of sanctions frameworks, screening processes, the management of screening hits, and experience of sanctions licensing and money laundering defence processes
- Strong understanding of AML/CFT risk methodologies, including country risk, sector risk and customer/investor risk rating frameworks
- Proven ability to engage with external authorities, regulators and law enforcement at a senior level, with strong written and verbal communication skills
- Ability to manage competing priorities across multiple regulatory mandates with confidence, sound judgement and personal integrity
- Excellent stakeholder engagement skills, with the ability to present complex financial crime matters clearly to Boards, senior management and regulators.
- A proactive, solutions-oriented mindset with a high degree of personal integrity and professional judgement
- A relevant professional qualification in compliance, law, or financial crime (e.g. ICA, CAMS, legal qualification)
WHAT WE OFFER
We are committed to supporting your development, advancing your career, and providing benefits that matter to you.
Our industry-leading Alter Domus Academy offers six learning zones for every stage of your career, with resources tailored to your ambitions and resources from LinkedIn Learning.
Our global benefits also include:
- Support for professional accreditations such as ACCA and study leave
- Flexible arrangements, generous holidays, plus an additional day off for your birthday!
- Continuous mentoring along your career progression
- Active sports, events and social committees across our offices
- 24/7 support available from our Employee Assistance Program
- The opportunity to invest in our growth and success through our Employee Share Plan
- Plus additional local benefits depending on your location
Alter Domus is an Equal Opportunity Employer: Equity Statement
All qualified applicants will receive consideration for employment without regard to race, color, religion, sex, national origin, disability, or protected veteran status.
(Alter Domus Privacy notice can be reviewed via Alter Domus webpage: https://alterdomus.com/privacy-notice/)