Compliance Manager (AML/CFT & Principal Officer)

Job Summary:

The Compliance Manager is a critical full-time regulatory role responsible for overseeing the entity’s adherence to the Non-Bank Financial Institutions Regulatory Authority (NBFIRA) legal framework. This role combines the functions of the Principal Officer (PO) and the AML/CFT Compliance Officer, ensuring the company operates within the Micro Lending Regulations (2012), the Financial Intelligence Act (2019), and the NBFIRA Act (2016).  As a Key Management Personnel (KMP) position, the successful candidate must satisfy the NBFIRA Fit

and Proper Rules (2017) and undergo formal vetting by the Authority.

Key responsibilities:

• Regulatory Compliance & Principal Officer Duties
• Serve as the primary liaison between the company and NBFIRA, ensuring all reporting deadlines and licensing conditions are met.
• Ensure full compliance with the Micro Lending Regulations (2012) and other relevant financial services laws in Botswana.
• Oversee the implementation of the Loan Underwriting and Credit Policy to ensure borrowers’ creditworthiness is assessed in line with Regulation 9 of the Micro Lending Regulations.
• Manage the Comprehensive Complaints Policy, ensuring a complaints register is maintained and that unresolved disputes are referred to NBFIRA as required.
• Ensure that all standard loan agreements and Consent of Spouse forms comply with Forms 4 and 5 of the Micro Lending Regulations.
• AML/CFT & Financial Intelligence
• Act as the designated AML/CFT Compliance Officer, ensuring the entity complies with the Financial Intelligence Act and the Regulations of 2019.
• Develop and maintain internal Anti-Money Laundering and Combating of Financial Terrorism and Proliferation (AML/CFT) policies and controls.
• Establish robust Know Your Customer (KYC) guidance and customer due diligence procedures.
• Conduct regular staff training programmes on identifying and preventing financial crimes to prevent criminals from laundering proceeds obtained from criminal activities.
• Governance and Risk Management
• Maintain the proposed organisational structure, ensuring the roles of Principal Officer and AML/CFT Compliance Officer remain clearly identified.
• Ensure the entity maintains the minimum financial liquidity requirement of P20,000 at all times.
• Monitor and enforce the Bad Debts/Delinquency Policy, ensuring that penalties do not exceed 5% of the outstanding principal amount per month.
• Oversee the Service Level Agreements for any third-party agents or micro-lending agents used by the company.

Qualifications and Experience:

• A Bachelor's degree in Law is preferred, but someone with a degree in a relevant field will be considered.
• 6+ years of experience in AML, data protection, and compliance roles, preferably within the FinTech or financial services industry.
• Professional certification in Anti-Money Laundering (e.g., CAMS, ICA International Diploma in Anti-Money Laundering).
• Professional certification in data protection (e.g., CDPS, CIPP/E, CIPM, CIPP/A, CIPT, CDPO).
• Strong demonstrable understanding of global standards, laws and regulation for AML and data protection.
• Proven experience in developing and implementing compliance, AML and data protection frameworks, policies, and procedures.
• Proficiency in conducting DPIA, managing data breach incidents, liaising with regulators.

Preferred Qualifications:

• Fluency in French would be highly advantageous.
• Experience working with large-scale data processing systems and technologies.
• Company overview: Ezra provides B2B digital lending solutions for emerging markets in partnership with mobile and digital wallet operators and financial service providers. Ezra supports 24 operations in 23 countries, across Africa, the Middle East and Asia. Our key office locations are in Nairobi, Kenya and Dubai, UAE.
• Our flagship products are Airtime Credit Services (ACS), Nano and BNPL.
• ACS is an airtime or data advance offered to prepaid mobile subscribers at the point of low credit.
• Nano is a micro cash advance offered to mobile wallet users on demand.
• BNPL facilitates payment installments for products and services
• As a FinTech company, our business is entirely technology and data driven, from determining subscriber eligibility, generating relevant offers, managing risk, loan issuance, recovery, optimizing performance and reporting, reconciliation and billing.
• Each day we process approximately 21M loan requests and 1.4 TB of data across our markets. This process needs to be robust, reliable and secure.
• But it doesn’t end there. We’re exploring new ways of using our platform and transactional data to improve our products and develop new product opportunities.