Head of Unit - Anti Financial Crime and Conduct (AFC&C) & MLRO (f/m/d)

Clearstream Banking S.A. • Luxembourg

Learn. Develop. Grow. But always: Share value

Join our international team that drives positive change, united by a spirit of openness and curiosity. We empower you to have an impact and to grow – personally and professionally. With us, you work at the heart of financial systems and evolve the way markets operate. We’re excited about the future because we are the ones shaping it. Let´s do this together by sharing value!

Who we are

Who we are

Tracing its origins to 1585, Deutsche Börse Group has become one of the world’s leading exchange organisations and an innovative market infrastructure provider. In this role, we provide investors, financial institutions and companies access to global capital markets. What’s your part in all this? With your commitment you contribute to the success of our unique business model: offering a wide range of products, services and technologies for security, transparency and integrity on the markets. By creating trust in the markets of today and tomorrow we foster growth and contribute to the prosperity of future generations.


Your career at Deutsche Börse Group

Your area of work: 

The Head of Unit Clearstream Anti Financial Crime and Conduct (AFC&C) and Money Laundering Reporting Officer (MLRO) is responsible for implementing measures to combat money laundering (AML), terrorist financing (CTF) and other criminal offence including Prevention of Market abuse, and Whistleblowing process (OCO). This includes ensuring compliance with relevant Anti-Money-Laundering Act laws and regulations, including Customer Due Diligence (CDD) activities, as well as the prevention of terrorist financing and other criminal offence including Prevention of Market abuse, Whistleblowing regulations and policies. The Compliance Function works closely with the individual business units and group control functions to ensure compliance with national and international laws and regulations applicable to the various units of the Deutsche Börse Group and its business activities. The compliance function has a proactive role in the identification of possible non-compliance or reputational risks, including those that may arise in connection with new activities and products. Clearstream Compliance works in partnership with Group Compliance which is responsible in defining group-wide compliance policies, supports their uniform application within the group entities, and provides centralised services to prevent money laundering and terrorist financing, international financial sanctions, anti-corruption, data protection, and the prevention of conflicts of interest and related securities law requirements.


Located in Luxembourg the Head of Unit Clearstream Anti Financial Crime and Conduct (AFC&C) and Clearstream Luxembourg MLRO contributes to the success of the overall Clearstream Compliance function embedded in a broader compliance approach across the Deutsche Börse Group and Clearstream Sub-Group. The Head of Unit AFC&C will bring leadership and matter expertise on Anti Financial Crime and Conduct and MLRO tasks and will contribute to the overall strengthening of Compliance activities and processes.  


Your responsibilities:

  • Establish and maintain risk area-specific framework / documentation for AML/CTF including CDD and OCO. Especially:

    • Annual and ad-hoc (if required) update of the AML/CTF-related Policies
    • Define and annually review the Client Risk Rating Methodology
    • Annual and ad-hoc (if required) update of the relevant 2LoD procedures
    • Conduct, revise and document AML/CTF & OCO Risk Analysis, at least on an annual basis and obtain approval from Executive Management


  • Advise on requirements and oversee the business's implementation of the KYC process for customer identification and verification, assess information obtained by the business, conduct own red-flag assessments and sign-off or withhold approval for new and existing customers (as part of client onboarding as well as periodic and ad-hoc reviews). Especially:

    • Assess information obtained by the business 1st LoD

    • Identify potential red flags, raise for clarification and potentially impose control activities

    • Signing-off or withholding approval of escalations for new or existing customers

    • Assign Compliance risk classification and impose additional risk mitigation measures as necessary and appropriate. Especially:

    • Review and assign the client risk classification

    • Impose additional risk mitigation measures as necessary and appropriate


  • Implementation and execution of internal safeguards. Especially:
    • Advise on processes for reliability checks conducted to assess reliability of relevant employees

    • Opine on AML/CTF-relevant aspects in relation to Material Change Process (including new products and services, significant reorganizations, and mergers and acquisitions)


  • AML/CTF and OCO reporting. Especially:

    • Annual AML/CTF and OCO reporting (embedded into Compliance Annual Report)

    • Quarterly reporting (embedded into Quarterly Compliance Report)


  • Ensure prompt submission of SARs to relevant supervisory authorities - involve Chief Compliance Officer upon reporting

  • Ensure execution of risk area-specific trainings. Especially:

    • Develop training measures (usually web-based courses) to raise staff awareness on AML/CTF and Fraud requirements and respective staff obligations

    • Deliver the recurring training courses according to required frequency and track course completion

    • Perform ad-hoc trainings for dedicated target groups on specific topics


Your profile:

  • University degree in law, finance or a relevant comparable qualification

  • 10+ years management experience (line management responsibility for teams of 5+ people) in EU regulated financial institutions

  • 5+ years experience in the Compliance (2nd line of defence) function of EU regulated financial institutions

  • Experience in the MLRO role in Luxembourg or international regulated financial institutions

  • Detailed understanding of the EU custody and post-trade business

  • Detailed knowledge of EU and Luxembourg legal and regulatory framework – and 5+ yrs experience of its implementation and operation in Luxembourg financial institutions - about AML, KYC, Other Criminal Offences / Fraud, Prevention of Market abuse, Whistleblowing

  • Experience of leading teams, manage senior stakeholders and operate in complex matrix organization, multicultural environment, in a multi-location setup

  • Experience in establishing and governing regulatory-relevant outsourcing arrangements

  • Excellent command of spoken and written English; French and German are a plus

  • Strong organizational skills and ability to cope with tight deadlines and handle multiple priorities whilst being solution driven and client focused

  • Communication and negotiation skills, including ability to present complex matters in a clear and comprehensive way

  • Strong individual initiative, high level commitment and motivation

Why Deutsche Börse Group?

We are committed to providing a work environment where everyone feels welcome and can reach their full potential. Our standards go far beyond simply matching candidates with the right position.


We enable you to move freely with our job tickets, job (e-)bikes and free parking opportunities.

Work environment

Collaboration, communication, or deep focus – in our modern office buildings you will find the perfect work environment. Free drinks and food and meal allowances included.

Health and wellbeing

We care for your health and wellbeing and besides various health promotion measures we offer you a group accident insurance and additional insurance offers at discounted rates.

Financial stability

We provide financial stability by offering attractive salaries, company pension schemes, participation in our Group Share Plan, as well as bonuses, subsidies and discounts.

Hybrid work

Collaborate and exchange on-site or work remotely several days a week in line with business needs and local regulations. Our hybrid working model combines the best of both worlds.

Flexible working hours

We want your job to fit your life situation and offer flexible working time models, part-time models, childcare allowance, or the possibility to study alongside your job.


Our market infrastructures are globally connected. Working with us means collaborating with like-minded colleagues across over 60 locations from more than 100 nations.


We promote individual development by offering internal development programmes, mentoring, further education and training budgets.

Ninwe Gourie – Campus Recruiting

Ninwe Gourie – Campus Recruiting

Are you interested in an internship, an apprenticeship or a working student job?


Our Campus Recruiting Team is looking forward to your call or e-mail.

Recruiting Team

Recruiting Team

Take your career to the next level with us and embrace new challenges!


Our Recruiting Team is looking forward to your call or e-mail.

Ready to start your career with us?

Apply now!