About the role
The TM function is mid-build across detection capability, operating model, and platform infrastructure. The Deputy Head will drive delivery across a complex, multi-jurisdictional operating model — translating regulatory expectations into working controls, challenging first-line frameworks with credibility and precision, and providing structured, evidence-based oversight of TM risk across the Group.
Responsibilities
- Shape and evolve the Group TM framework with the Head of TM — policies, procedures, rule design methodology, threshold calibration, and the quality assurance regime.
- Review and challenge Scenario Engineering outputs, rule specifications, threshold proposals, and back-testing results ahead of Head of TM sign-off.
- Own the quality bar for QA and Governance outputs, ensuring they meet the standard expected by senior management and regulators.
- Shape rule change proposals and threshold recalibrations through the change management process.
- Drive TM minimum standards across entities, partnering with local Heads of Compliance to close gaps.
- Approve withdrawal holds, account restrictions, and alert escalations.
- Review L3 SAR referral packs for completeness and evidential sufficiency before they go to the entity MLRO.
- Approve interim rule threshold changes that can’t be deferred, recording the rationale for the Head of TM to confirm on their return.
- Deputise fully for the Head of TM during leave or absence, holding full decision-making authority within the governance framework for that period.
- Support the Head of TM in managing regulator relationships on TM matters.
- Respond to supervisory queries, attend regulatory meetings, and represent the TM function at inspections.
- Support the preparation and delivery of regulatory submissions, responses to supervisory feedback, and remediation communications.
- Coordinate with entity MLROs and Heads of Compliance on jurisdiction-specific TM requirements.
- Provide day-to-day leadership and line management of TM specialist teams, alongside the Head of TM.
- Lead recruitment, onboarding, and development of TM analysts across pillars.
- Chair TM governance meetings, including in the Head of TM’s absence.
- Act as the senior escalation point for analysts, bringing decisions to the Head of TM where needed.
- Drive risk culture across the TM function through visible leadership, consistent challenge, and clear communication.
- Uphold the governance boundary between TM compliance decisions and commercial interests, escalating to the Group Head of Compliance and Regulatory Risk if the Head of TM is unavailable to resolve a conflict.
- Ensure 1LOD Alert Operations operates within the framework set by 2LOD, escalating any breach to the Head of TM.
- Maintain audit-ready documentation across all TM governance activity.
- Act as a senior escalation point for material TM issues, control failures, and emerging risks across all entities
TM Framework & Policy
Delegated Authority & Decision-Making
Hold formal delegated authority from the Head of TM, stepping into the primary TM decision-maker role whenever they’re unavailable and a decision can’t wait. In this capacity, you will:
Regulatory Engagement
Working under the Head of TM’s direction, and independently when they’re unavailable, you will:
Team Leadership
Governance & Oversight
Requirements
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Extensive experience in financial crime compliance, with at least 3 years in a senior TM role (team lead, deputy head, head of TM, or equivalent) within a regulated financial services firm.
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Experience in the CFD, forex, or leveraged derivatives sector, or with investment firms offering similar products.
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Demonstrable experience making autonomous decisions on TM matters: alert escalation, SAR filing recommendations, account restriction approvals, and rule threshold adjustments.
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Experience engaging directly with the FCA or another Tier 1 regulator (CySEC, ASIC, MAS, BaFin) on TM or financial crime matters, including responding to supervisory queries and attending regulatory meetings.
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Experience with TM framework design or significant enhancement, including rule design methodology, threshold calibration, and quality assurance.
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Working knowledge of AML/CTF regulatory requirements in at least two of: UK (FCA/MLR 2017), EU/Cyprus (AMLD/CySEC), Australia (AML/CTF Act/AUSTRAC), UAE (CBUAE).
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Experience managing or overseeing a team of financial crime or TM specialists.
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Strong written and verbal communication: the role produces materials for senior management, the CCO, the Board, and regulators
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