The Opportunity We are seeking an experienced AML Compliance Officer to lead and evolve the Anti-Money Laundering (AML), Countering the Financing of Terrorism (CFT), and Sanctions Compliance Program for XR Pay, Inc. XR Pay is the payments and payroll division of XR Extreme Reach that pays commercial talent, production crew, independent contractors, and vendors on behalf of advertising agencies, brands, and production companies.
Reporting to the General Counsel, you will be the Board-designated officer with overall responsibility for the program. As XR Pay's payment operations grow, you will shape the program's next stage. That means refining controls, improving technology, and keeping the framework aligned with evolving regulatory expectations and leading industry standards.
Responsibilities - Program Leadership: Administer and oversee XR Pay's AML/CFT and sanctions program as the Board-designated officer. Act as the main contact for regulators, banking partners, and law enforcement. Maintain and refine the AML Program Document and its supporting procedures, and keep them current with regulatory change and evolving expectations in the jurisdictions where XR Pay operates.
- Governance & Reporting: Deliver quarterly reporting to the Executive Committee and an annual program review to the Audit Committee.
- Product & Engineering Partnership: Work side by side with R&D, Treasury and Operations teams to embed AML and sanctions controls into the XR Platform and payment workflows. Design, build, and implement compliance controls and tooling. Translate regulatory requirements into user stories, data requirements, and acceptance criteria, and support testing, rollout, and post-launch tuning. Lead and scale the AML compliance team as the business grows.
- Risk Assessment & Oversight: Own the AML/OFAC Risk Assessments, refresh them every 18-24 months, and leverage to set priorities for control improvements.
- Monitoring & Investigations: Run transaction monitoring and investigations, including writing and tuning monitoring scenarios. Oversee the investigation of high-risk activity and file Suspicious Activity Reports (SARs) in compliance with regulatory deadlines.
- Customer Due Diligence, Sanctions & Screening Governance: Supervise automated screening systems (PEP, SDN/OFAC, adverse media, risk ratings) for client onboarding, talent payroll disbursements, and vendor payments.
- Sanctions: Configure and manage screening of customers, payees, and vendors. Approve blocking and rejecting decisions and serve as XR Pay's OFAC point of contact.
- Audit & Authority Liaison: Serve as the primary point of contact for external regulatory audits, banking partner compliance inquiries, and law enforcement requests.
- Training & Policy Management: Drive company-wide AML training initiatives and draft clear, actionable compliance SOPs for cross-functional teams (Operations, Finance, HR, and Product).
- Records & Third Parties: Oversee record retention (5 years for AML records, 10 years for sanctions records). Build AML and sanctions risk factors into third-party risk reviews.
- Other duties as assigned by Management.
Requirements- Experience: 8+ years of dedicated AML/BSA and sanctions compliance experience including at least three years at an MSB, money transmitter, payment processor, or payroll provider.
- Certifications: CAMS (Certified Anti-Money Laundering Specialist) or CFE (Certified Fraud Examiner) required.
- Regulatory Expertise: Deep knowledge of the BSA and FinCEN regulations (31 CFR Chapter X), including MSB obligations, CDD and beneficial ownership, SARs, the Funds Transfer/Travel Rule, and 314(a). Deep knowledge of OFAC sanctions programs (31 CFR Parts 500-599), including blocking and reject reporting, and state money transmission regimes. Working knowledge of Canadian AML requirements and familiarity with international AML standards and cross-border payment risks are a plus.
- Technical Skills: Hands-on experience implementing and configuring screening, identity verification, transaction monitoring and case management tools (e.g., LexisNexis, World-Check, ComplyAdvantage, Actimize). Comfortable writing business requirements, working in agile product teams and using data (SQL or similar) to analyze alerts and finetune rules.
- Builder mindset: Thrives in a fast-moving technology company. Equally comfortable in a Board meeting and in a sprint review.
- Leadership: Comfortable presenting to the Board and executives. Able to work across Treasury, Vendor Solutions, Talent Operations, Technology, and Legal.
- Education: Bachelor's degree in Finance, Business Administration, Criminal Justice, or Law required; Juris Doctor (JD) is a strong plus.
*Pursuant to California's Pay Transparency Laws, the pay range for this position is $175,000-185,000; base pay offered may vary depending on job-related knowledge, skills, and experience. 
