DMLRO, SE
Trustly · Stockholm
Who We Are
At Trustly, we are building a smarter, faster, and more secure financial future by revolutionising the world of payments. As a global leader in Open Banking Payments, we are establishing Pay by Bank as the new standard at checkout, giving millions of consumers and merchants worldwide unparalleled freedom, speed, and ease.
Our ambition is to build the world's most disruptive payment network and redefine what the payment experience should feel like.
Trustly is a global team of innovators, collaborators, and doers. If you are driven by a strong sense of purpose and thrive in a dynamic, entrepreneurial, high-growth environment, join us and be part of a team that is transforming the way the world pays.
About the Role
Trustly is looking for a passionate and experienced compliance leader to join our Financial Crimes Prevention team as Swedish Deputy MLRO. Reporting to the Global MLRO, with a dotted reporting line to the EU Deputy MLRO, you will take ownership of our Anti-Money Laundering (AML) programme in Sweden, from strategic oversight to hands-on execution.
You will be appointed as Trustly's central function responsible (centralt funktionsansvarig) for its Swedish-regulated payment institution under 6 kap. 2 § of the Swedish Act (2017:630) on measures against money laundering and terrorist financing and Finansinspektionen's regulations (FFFS 2017:11), with direct reporting to the board of directors and managing director in that capacity. You will be the company's subject matter expert on AML, sanctions, and Know Your Customer / Know Your Business (KYC/B) matters in Sweden, advising business and product teams, engaging directly with Finansinspektionen and the Swedish Financial Intelligence Unit (Finanspolisen), and building a scalable and robust compliance framework that keeps pace with both a fast-changing regulatory landscape and a fast-growing business.
What You'll Do
1. As central function responsible, provide independent oversight and challenge of Trustly's AML programme across Swedish operations, monitoring and continuously controlling the company's compliance with the Swedish Act (2017:630) on measures against money laundering and terrorist financing, FFFS 2017:11, and the company's routines and guidelines, in accordance with 6 kap. 2 § of the Act (Lag (2017:630) om åtgärder mot penningtvätt - riksdagen.se http://riksdagen.se, https://www.riksdagen.se/sv/dokument-och-lagar/dokument/svensk-forfattningssamling/lag-2017630-om-atgarder-mot-penningtvatt-och_sfs-2017-630/ https://www.riksdagen.se/sv/dokument-och-lagar/dokument/svensk-forfattningssamling/lag-2017630-om-atgarder-mot-penningtvatt-och_sfs-2017-630/).
2. Under the supervision of the Global MLRO, serve as the subject matter expert on AML, EU sanctions, and KYC/B matters in Sweden, guiding business and product teams on compliance requirements for new products and markets.
3. Provide advice and support to the company's employees, contractors, and other persons participating in the business on rules concerning money laundering and terrorist financing, as part of your duties as central function responsible under FFFS 2017:11 (FFFS 2017:11 - lagen.nu http://lagen.nu, https://lagen.nu/fffs/2017:11 https://lagen.nu/fffs/2017:11).
4. Perform the central function responsible role independently of the functions and areas you monitor and control, and report regularly and directly to the board of directors and the managing director on the company's compliance with AML/CTF requirements, deficiencies identified and remedial measures, as required under FFFS 2017:11 (FFFS 2017:11 - lagen.nu http://lagen.nu, https://lagen.nu/fffs/2017:11).
5. Enhance, localise, and manage effective AML, sanctions, and KYC/B compliance programmes aligned with Trustly's overall Financial Crime Programme and risk profile, including policies and standards on KYC/B, transaction monitoring, suspicious activity reporting, and sanctions screening for Sweden.
6. Develop a thorough understanding of Trustly's businesses, risks, and processes with respect to AML and sanctions compliance.
7. Support the general risk assessment and provide subject matter expert input into new business initiative risk assessments.
8. Act as primary liaison with Finansinspektionen, Finanspolisen, auditors, and partners for AML programme inquiries in Sweden, and work collaboratively with the Financial Crimes Prevention team to prepare and manage regulatory examinations and third-party audits and to ensure timely and accurate responses.
9. Collaborate with the Assurance Manager as they execute the compliance testing plan to assess the effectiveness of AML programme controls.
10. Deliver insights and communication on the state of the AML programme to the Global MLRO and, through the dotted reporting line, the EU Deputy MLRO, and coordinate your board reporting as central function responsible with their reporting to senior leadership and board-level committees.
11. Ensure the creation and delivery of AML and sanctions training to Trustly employees in Sweden in accordance with Swedish and EU-wide regulations.
12. Monitor legal developments, industry trends, and best practices, including readiness for Regulation (EU) 2024/1624 (AMLR) when it becomes applicable on 10 July 2027, to keep Trustly at the forefront of applicable requirements and maintain up-to-date knowledge of relevant laws and regulations.
13. Perform additional special projects as needed by the Global MLRO and the Financial Crimes Prevention team.
Who You Are
1. 8+ years of compliance, risk management, or regulatory experience in the financial services, fintech, or payments industries, preferably within a licensed or authorised payment institution.
2. Subject matter expertise in the Swedish Act (2017:630) on measures against money laundering and terrorist financing and Finansinspektionen's regulations (FFFS 2017:11), the EU AML framework (including the AMLR and AMLD6), and EU sanctions regimes.
3. Experience advising on and implementing compliance programme policies and procedures, including KYC/B, Enhanced Due Diligence, transaction monitoring, and suspicious activity reporting.
4. Strong understanding of the three lines of defence model and experience in a second line oversight role, ideally as, or deputy to, a central function responsible or MLRO at a Swedish-regulated institution.
5. Experience engaging with Finansinspektionen, the Swedish Financial Intelligence Unit, customers, and partners.
6. Experience conducting risk assessments and supporting audits by regulators, banks, and other third parties.
7. Excellent written and oral communication skills, including fluency in Swedish and English.
8. Ability to work under pressure and multitask.
9. Proactive, with an ability to take initiative, assume responsibility, and apply strong analytical skills.
10. ACAMS certification strongly preferred.
WHAT WE OFFER
At Trustly, you will have the chance to solve meaningful challenges alongside some of the brightest minds in FinTech. Together, we are shaping the future of payments in an environment that celebrates curiosity, collaboration, and innovation. You will be challenged and empowered to grow, making a real impact every step of the way.
Our team is as diverse as the global footprint we serve. At Trustly, we foster a workplace where everyone feels they belong—a place where teamwork thrives, ideas flourish, and we never forget to have fun along the way. We are proud and committed to being an Equal Opportunity Employer and believe an open and inclusive environment enables people to do their best work.
Our Fantastic Benefits (varies by location)
🌴 20 to 30 days of holiday to support a healthy work-life balance
🥳 Monthly team outing allowance to enjoy social events with your colleagues
👶 Parental leave top-up additional support for new parents
☕ On-site perks to make your workday smoother
💚 Well be