1. Qualification requirements

1.1. Level of Education: Bachelor’s or master’s degree in law, Economics, Finance, or Management.

1.2. Field of Education: Degree in Risk Management, Law, Business Administration, Economics, Finance, or a related field.

1.3. Professional Experience (duration in years, area of expertise):

• Minimum 3 years of experience in AML/CFT, financial monitoring, or compliance.
• Knowledge of AIFC AML Rules, AFSA Guidance, Kazakhstan AML/CFT Law, and FATF Standards.
• AML certifications (e.g., CAMS, ICA, ACAMS) are required or highly desirable.

1.4. Knowledge and skills required for performing duties:

• Strong analytical skills, attention to detail, integrity, and independence.
• Fluency in English (Intermediate level or higher).
• Ability to handle confidential information with discretion.

1.5. Licenses and certificates. Possession of one of the following international certificates in the field of compliance, audit, risk management and internal control would be considered an advantage:

• Certificate / Diploma in Compliance/AML/CFT.
• ISO 31000, CAMS, ICA, ACAMS.

The above list is not exhaustive, other relevant internationally recognized certificates may also be considered.

2. Description of functional responsibilities:

2.1. Fraud, AML/CFT, and Sanctions Compliance:

• Ensure compliance with AIFC AML/CFT and Sanctions Rules, the Republic of Kazakhstan AML/CFT Law, and other applicable regulations.
• Assess the adequacy and effectiveness of AML policies and procedures and provide recommendations for improvements.
• Monitor the execution of AML functions as prescribed by internal company policies.

2.2. Customer Due Diligence (CDD/EDD):

• Collect and verify customer identification information prior to establishing business relationships.
• Conduct CDD and Enhanced Due Diligence (EDD) for high-risk clients, changes in client circumstances, or complex ownership structures.
• Monitor clients for PEPs (Politically Exposed Persons) and UBOs (Ultimate Beneficial Owners).

2.3. Transaction Monitoring:

• Monitor transactions to identify suspicious activities or deviations from normal patterns.
• Apply a risk-based approach in analyzing transactions.
• Maintain automated monitoring systems, where applicable.

2.4. Suspicious Activity / Transaction Reporting:

• Receive internal notifications (internal SARs) of suspicious activity from employees.
• Prepare and submit Suspicious Activity Reports (SARs) to the FIU via AFSA in accordance with AIFC AML Rules and national AML/CFT legislation.
• Maintain a register of submitted SARs/STRs and confirmations from the regulator.

2.5. AFSA AML Return & Reporting

• Prepare and submit the annual AML Return Form to AFSA.
• Notify AFSA of material breaches in AML processes, audit results, changes in the AML framework, or MLRO appointments.
• Maintain ongoing communication with AFSA and FIU regarding AML matters.

2.6. AML Risk Assessment

• Develop and maintain the company-level ML/TF Risk Assessment.
• Identify risks related to clients, products, countries, and channels.
• Update Customer Risk Assessments and Business Risk Assessments at least annually.

2.7. Independent Audit and Testing

• Organize independent testing or audits of the AML program (internal or external).
• Monitor remediation of identified deficiencies.

2.8. Training and Awareness

• Conduct regular AML/CFT training for employees (at least annually).
• Develop training materials, maintain training records, and test knowledge.
• Ensure staff awareness of emerging money laundering schemes and legislative changes.

2.9. Record-Keeping

• Retain all AML-related documentation (CDD/EDD files, reports, correspondence with regulators) for a minimum of 5 years.
• achives in a secure and accessible manner for AFSA/FIU inspections.

2.10. Communication and External Relations

• Represent the company in interactions with AFSA, FIU, law enforcement, and other competent authorities.
• Respond to AFSA/FIU requests with formal written replies.
• Maintain trusted professional relationships with external auditors, consultants, and government agencies.

2.11. Execute other assignments and instructions issued by the Compliance Officer and the SEO within the scope of the company’s operations and regulatory framework.