Group MLRO (m/f/d)

About the Position

We’re looking for a Group MLRO to join our team in Berlin. If you want to help us make self-employment a little easier, Holvi is for you.

We 💛 small business

We founded Holvi in 2011, in Helsinki. As self-employed people wading through oceans of paperwork, we noticed something funny going on – traditional banks were giving us the cold shoulder. Why not help ourselves? We asked. And so, with time and effort (and lots of coffee), we mastered small business finance – and Holvi was born.

Our vision is simple: Eliminate the distractions of financial admin and simplify work life, because running a business is hard enough. Small businesses shouldn’t have to worry about spreadsheets and lost receipts.

Since our inception as a pioneering fintech, we've experienced our fair share of challenges and growth. We explored different paths, and from those experiences, we've evolved. Today, we stand as a team-owned and profitable company, proud of our journey.

Right now, we’re looking for a Group MLRO to join our team in Berlin. If you want to help us make self-employment a little easier, Holvi is for you.

Responsibilities

As Group MLRO, you will:

• Shape the AML strategy and roadmap, aligning the first line behind it and guiding Holvi through regulatory change such as AMLR, with readiness you can evidence
• Evolve our customer risk methodology, policies, controls, tooling, and training as our customer portfolio and product range grow
• Assess new products and changes across their lifecycle, and link those assessments to the BWRA
• Test core 1LOD processes (TM, screening, CDD, SAR/STR, freezing, and offboarding) and drive gaps to resolution
• Lead regulatory exchanges, audits, thematic reviews, and annual reporting, while keeping an eye on regulatory developments and market practice
• Report to the Board and Risk Committee with clear, data-led metrics, and advise on risk appetite and KRIs
• Steer the priorities of our country MLROs and oversee partner and outsourcing compliance and adjacent areas such as fraud, anti-bribery and corruption, and whistleblowing

Requirements

• Several years of AML/CTF experience at a regulated financial institution, including as MLRO or deputy MLRO, and hold a relevant certification (e.g. CAMS, ICA)
• In-depth knowledge of the EU AML framework and experience handling supervisory exchanges (e.g. with BaFin), audits, and regulatory reviews end to end, including remediation
• Experience in designing or evolving customer risk scoring models, BWRAs, or similar methodologies, and understanding TM, screening, and CDD tooling, including tuning and validation
• Ability to turn complex risk topics into clear Board reporting and practical guidance for business teams
• Hands-on builder who brings structure to a scaling company and gives risk-based judgment rather than hiding behind policy papers
• Lead through influence, aligning peers and stakeholders in fluent English and German

Nice to Have

• Knowledge of SME/B2B payments, credit, or FX products
• Oversight experience across multiple countries or MLRO structures
• Experience in fraud, ABC, or sanctions evasion
• Comfortable working with data (e.g. SQL, dashboards)

We Offer

• Employee stock options – Opportunity for equity in Holvi
• Flexible working – Flexible working hours and possibilities for remote working
• Monthly benefit budget that can be used in multiple ways
• Work-life balance – Weekly exercise hour, bi-weekly breakfasts, bi-annual team weeks, and more
• A team of compliance, risk, and AML experts working together side-by-side
• The chance to shape this role around what's good for you and Holvi

Logistics

• This is a full-time, permanent position in our 2LOD team
• You’ll be headquartered in our office in Berlin, with two days a week of office presence expected
• Due to the regulatory nature of this role, the appointment is subject to notification to, and assessment by, the competent supervisory authorities, as well as a background check including a criminal record check

About Holvi Payment Services

We founded Holvi in 2011, in Helsinki. As self-employed people wading through oceans of paperwork, we noticed something funny going on – traditional banks were giving us the cold shoulder. Why not help ourselves? We asked. And so, with time and effort (and lots of coffee), we mastered small business finance – and Holvi was born.

Founded in 2011, Holvi is a team-owned and profitable company with 142 co-workers and a turnover of 20M.

Equal Opportunity Statement

At Holvi, we embrace diversity in all of its forms and foster an inclusive environment for all people to live their best work life. This is central to our mission of promoting a healthy balance in all things we do.

We're an equal opportunity employer. All applicants will be considered for employment without attention to ethnicity, religion, sexual orientation, gender identity, family or parental status, national origin, veteran, neurodiversity status, or disability status.