Head of Compliance
AstroPay
Job Type
Description
Head of Compliance IOM
AstroPay Global (IOM) Limited, a Class 8 (sub-classes 2(a) and 4) licenceholder regulated by the Isle of Man Financial Services Authority (IOMFSA), is seeking a dedicated and experienced Head of Compliance (HoC) for its Isle of Man operations. This is a senior role holding the R13 Controlled Function status under the IOMFSA regime, requiring the individual to be resident in the Isle of Man and meet the IOMFSA's Fitness and Propriety standards on an ongoing basis.
The HoC will be responsible for establishing, managing, and overseeing the effectiveness of the company's compliance framework, ensuring adherence to all applicable Isle of Man regulatory requirements, including the Financial Services Act 2008, the Financial Services Rule Book 2016, the Regulated Activities Order 2011, and the AML/CFT Code. This includes overseeing compliance monitoring, policy development, regulatory reporting, risk management (across financial, legal, regulatory, and operational domains), and acting as a key liaison with the IOMFSA and other stakeholders.
The role is critical in maintaining AstroPay's regulatory standing and mitigating compliance risks within the Isle of Man.
Responsibilities
Key Responsibilities:
Regulatory Compliance & Framework Management:
Act as the R13 Head of Compliance Controlled Function holder for AstroPay Global (IOM) Limited, fulfilling all associated responsibilities and maintaining fitness and propriety.
Oversee compliance with all conditions of the AstroPay Global (IOM) Limited licence and applicable Isle of Man regulatory requirements (including the Financial Services Act 2008, Financial Services Rule Book 2016, AML/CFT Code, Data Protection Act etc.).
Establish, maintain, and oversee robust, documented arrangements (policies, procedures, systems, and controls) appropriate to the nature, scale, and complexity of the business (Class 8(2a) & (4)) for compliance with all regulatory requirements.
Ensure appropriate segregation of duties, safeguarding of client assets (including relevant funds under Class 8 rules), maintenance of records, and fair treatment of clients.
Develop, implement, and manage the Compliance Monitoring Program (CMP), ensuring compliance activities are effectively tracked, assessed, and reported.
Ensure prompt action is taken to remedy any identified deficiencies in compliance arrangements or controls.
Maintain statutory registers required by the Rule Book, including those for Conflicts of Interest (Rule 8.10), Breaches (Rule 8.17), and Complaints (Rule 8.32).
Risk Management & Internal Controls:
Establish and maintain comprehensive policies for managing financial, legal, regulatory, operational, and group-related risks.
Ensure appropriate procedures and controls are in place for identifying, measuring, monitoring, and controlling relevant risks.
Oversee the effectiveness of the company's internal controls framework related to compliance and risk.
Ensure the business resumption and contingency arrangements (Rule 8.14) are appropriate and tested.
Policy Development & Maintenance:
Develop, review, implement, and update compliance policies and procedures (including the Compliance Manual, Risk Management Policy, Conflicts of Interest Policy, Whistleblowing Policy, etc.) ensuring they align with IOM regulatory requirements and industry best practice.
Ensure policies are effectively communicated and embedded within the business.
Regulatory Liaison & Reporting:
Act as a primary point of contact for the IOMFSA on compliance matters, fostering an open, honest, and cooperative relationship.
Manage regulatory inquiries, examinations, audits, and reporting requirements for the Isle of Man.
Prepare and present timely and accurate compliance reports to the Board of Directors, Group CCO, senior management, and, where required, the IOMFSA.
Ensure timely notification to the IOMFSA of required matters under Parts 7 and 8 of the Rule Book (e.g., breaches, changes in structure/activities, key person changes, complaints metrics etc.).
Leadership, Training & Advisory:
Provide leadership, oversight, and guidance to the MLRO.
Develop and oversee the delivery of relevant compliance training programs for Isle of Man employees, ensuring alignment with regulatory requirements and business needs.
Provide expert compliance advice and guidance to business units and senior management on regulatory matters, new products/services, and strategic initiatives.
Promote a strong compliance culture throughout the Isle of Man operation.
Controlled Function Oversight:
Possess sufficient knowledge and understanding to oversee compliance aspects related to other Controlled Functions within the IOM entity.
Participate in the due diligence process for proposed Controlled Function holders, ensuring fitness and propriety assessments are conducted thoroughly before notification/application to the IOMFSA.
Where authorised by the Board, sign regulatory declarations on behalf of the regulated entity related to Fitness and Propriety (e.g., on F&P 1 and F&P 2 forms).
Core Competencies and Skills:
Regulatory Knowledge - Deep understanding of the Isle of Man financial services regulatory framework, including the Financial Services Act 2008, Financial Services Rule Book 2016 (especially Parts 6, 7, 8), Regulated Activities Order 2011, AML/CFT Code, Data Protection legislation, and relevant IOMFSA Guidance (including Fitness & Propriety, Corporate Governance, Training & Competence). Specific knowledge relevant to Class 8 licences (Payment Services/E-money) is essential.
Nice to Have:
Experience with AI-powered compliance technology or data analytics.
Experience in managing compliance across multiple jurisdictions (understanding group context).
Spanish language skills.
Requirements
Experience and Expertise:
Minimum 5 years of compliance experience within the financial services sector, with experience in a senior compliance role.
Hold a relevant professional qualification.
Experience within the FinTech, Payment Services, or E-Money industry is highly desirable.
Proven experience in building and managing compliance frameworks and dealing directly with regulators (specifically the IOMFSA).
Fitness & Propriety:
Demonstrable integrity, competence, capacity, and sound financial standing, meeting the IOMFSA's requirements for holding a Controlled Function.
Leadership & Management: Proven ability to operate with appropriate independence and influence senior management and the Board. Experience in overseeing compliance professionals.
Policy & Procedure Development:
Expertise in drafting, implementing, and maintaining clear and effective compliance policies and procedures.
Risk Management: Proficient in compliance risk identification, assessment, mitigation, and monitoring.
Communication Skills:
Excellent written and verbal communication skills, with the ability to articulate complex regulatory requirements clearly to various audiences (Board, staff, regulators).
Stakeholder Engagement:
Proven experience in effectively engaging with regulators (IOMFSA), auditors, and other key internal and external stakeholders.
Educational Background: Bachelor's degree in Law, Finance, Business, or a related field. Relevant professional compliance qualifications (e.g., ICA Diploma) are highly advantageous.
Key Objectives for the First 6 Months:
Gain a comprehensive understanding of the existing AstroPay (IOM) compliance framework, policies, and procedures.
Conduct an initial assessment of the framework against IOM regulatory requirements, identifying potential gaps or areas for enhancement.
Develop a detailed action plan outlining proposed improvements and timelines for implementation.
Establish strong working relationships with the IOMFSA supervision team, the IOM Board, Group CCO, the MLRO, and other key internal stakeholders.
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