Money Laundering Reporting Officer (MLRO)

Company: Most Investment Limited
Industry: Venture Capital / Managing Collective Investment Scheme (AIFC)
Location: Astana or Almaty (remote / hybrid possible)
Employment type: Full-time (part-time may be considered)

Most Investment Limited is a venture capital firm managing funds under a Collective Investment Scheme license within the Astana International Financial Centre (AIFC).

We are looking for a Money Laundering Reporting Officer (MLRO) to join our team and be responsible for AML/CFT oversight in accordance with AIFC and Kazakhstan regulatory requirements.

Key Information About the Role

• The MLRO is an Approved Individual under the AIFC General Rules
• The role reports directly to the Board of Directors and/or Senior Management
• The MLRO acts independently when performing AML/CFT functions
• Astana or Almaty preferred; part-time engagement may be considered subject to AFSA approval
• The candidate must be willing and able to successfully pass an interview with the Astana Financial Services Authority (AFSA)

Qualification Requirements

The successful candidate should meet the following criteria:

• Bachelor’s degree in law, finance, economics, or a related field
• Legislation of the Astana International Financial Centre (AIFC) and the Republic of Kazakhstan
• At least 3 years of professional experience in AML/CFT within the financial sector (banks, investment firms, asset managers, funds, etc.)
• Strong knowledge of:
  • AML/CFT legislation of the Republic of Kazakhstan
  • AIFC AML Rules and AFSA regulatory requirements
  • Client due diligence (CDD), enhanced due diligence (EDD), and transaction monitoring/reporting
• Fluent English is mandatory (for regulatory communication, reporting, and internal documentation)
• Impeccable business reputation, high professional integrity, no unexpunged criminal record
• Appointment is subject to approval by the Astana Financial Services Authority (AFSA)

Key Responsibilities

• Perform the functions of MLRO in accordance with AIFC AML Rules, the AML/CFT Law of the Republic of Kazakhstan, and other applicable regulations
• Develop, implement, and maintain the Company’s AML/CFT framework, including policies, procedures, and internal controls
• Ensure effective client due diligence (CDD), enhanced due diligence (EDD), and ongoing monitoring of clients, investors, counterparties, and transactions, considering the specifics of venture capital and managing Collective Investment Schemes
• Identify, assess, and monitor money laundering and terrorist financing risks related to the Company’s business and fund structures
• Identify suspicious transactions and determine the necessity of submitting reports to the Agency for Financial Monitoring (AFM) and notifying AFSA in accordance with internal procedures
• Ensure timely and accurate submission of AML/CFT reports to competent authorities
• Maintain proper record-keeping of CDD documentation, transaction records, internal reviews, and correspondence with regulators
• Prepare regular AML/CFT reports for Senior Management and the Board of Directors, including risk assessments and recommendations
• Coordinate and oversee employees involved in AML/CFT processes, including those with partial AML responsibilities
• Organize and conduct AML/CFT training for employees and senior management
• Ensure confidentiality of information obtained in the course of performing MLRO duties.