Money Laundering Reporting Officer (MLRO)

As Shopify seeks our EU Electronic Money Institution (EMI) licence, we are looking for an experienced compliance Money Laundering Reporting Officer (MLRO) to lead our local Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) efforts. You will be responsible for supporting the licensing process, and, post-authorisation, the execution of the AML/CTF and suspicious activity programme to ensure we are meeting regulatory expectations.
TEAM OVERVIEW
Within the Shopify Legal Team, the Compliance Team aims to ensure that Shopify is compliant with regulatory and contractual commitments while remaining agile to encourage growth and innovation. As Shopify continues to expand its financial products and services, we’re also expanding our Compliance Programme to support Shopify’s mission of making commerce better for everyone. Our team designs and enforces policies and controls that ensure Shopify complies with applicable laws and regulations so our merchants, partners, and third parties can trust us.
KEY RESPONSIBILITIES
- Support our effort to obtain an EMI licence in Luxembourg, including providing input into the design of our AML/CTF programme to align with Luxembourg's financial crimes regulations.
- Implement and operationalise the local AML/CFT programme from the ground up, while partnering with the global/UK AML programme to keep standards consistent and preserve local independence.
- Respond to inquiries from the Commission de Surveillance du Secteur Financier (CSSF) and other relevant authorities on financial crime matters.
- Maintain and execute the local entity’s risk-based AML/CTF programme, including the risk assessment, policies, and controls.
- Lead Luxembourg suspicious activity reporting: receive internal escalations, make STR/SAR filing decisions, submit reports to the Cellule de Renseignement Financier (CRF), and manage post-filing follow-up information requests.
- Monitor AML operations performance and effectiveness, including AML/KYC standards, transaction monitoring and screening governance, and conduct QA/testing and training.
- Provide regular reporting to the Head of Risk & Compliance and the entity’s board; support CSSF reporting and engagement on AML/CFT matters as needed; escalate material issues promptly to management and the board.
- Maintain audit/exam readiness and drive remediation of AML/CTF findings.
JOB REQUIREMENTS
- Significant experience in an EU-regulated financial institution (payments/e-money strongly preferred), including ownership of a risk-based AML programme.
- Direct MLRO experience or demonstrably equivalent responsibility, such as deputy MLRO, FIU lead, or AML compliance officer with responsibility for filing decisions and submitting STR/SARs.
- Strong working knowledge of EU and local Luxembourg AML expectations for payments/e-money firms, including risk assessments, CDD/EDD, transaction monitoring, sanctions screening, investigations, and recordkeeping.
- Experience working collaboratively in building or scaling AML controls for new products, high-growth volumes, or distributed operations teams.
- Demonstrated ability to work effectively with a management board and to provide concise, defensible escalation and reporting.
- Experience responding to regulatory requests and managing audit/exam activity and remediation.
- Ability to meet CSSF’s “fit and proper” expectations for a regulated key control role (including background screening).
- Residency in Luxembourg with the ability to commute to the office for in-person meetings, as needed (e.g., with regulators, financial partners).
- Advanced English language skills.
Nice to have:
- CAMS / ICA or comparable AML certification.
- French language skills.