Group MLRO (m/f/d) - #2765944

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.

Leading AML oversight

As Group MLRO, you report to our Chief Risk & Compliance Officer (2LOD) and are formally and primarily appointed as MLRO for Germany. You are the functional lead for AML, CTF and sanctions across Holvi: you set priorities and roadmaps with the MLROs for Austria and Finland, oversee their output, and make sure everyone pulls in the same direction. This is a functional leadership role. You work closely with the CRO/CCO as the key advisor on AML strategy and priorities, and you’re the go-to person for regulators, auditors and the Board on financial crime.

A typical day could see you:

• Shaping 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
• Evolving our customer risk methodology, policies, controls, tooling and training as our customer portfolio and product range grow
• Assessing new products and changes across their lifecycle, and linking those assessments to the BWRA
• Testing core 1LOD processes (TM, screening, CDD, SAR/STR, freezing and offboarding) and driving gaps to resolution
• Leading regulatory exchanges, audits, thematic reviews and annual reporting, while keeping an eye on regulatory developments and market practice
• Reporting to the Board and Risk Committee with clear, data-led metrics, and advising on risk appetite and KRIs
• Steering the priorities of our country MLROs and overseeing partner and outsourcing compliance and adjacent areas such as fraud, anti-bribery and corruption, and whistleblowing
  
  

This is for you if you:

• Have 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)
• Know the EU AML framework in depth and have handled supervisory exchanges (e.g. with BaFin), audits and regulatory reviews end to end, including remediation
• Have designed or evolved customer risk scoring models, BWRAs or similar methodologies, and understand TM, screening and CDD tooling, including tuning and validation
• Can turn complex risk topics into clear Board reporting and practical guidance for business teams
• Are a hands-on builder who brings structure to a scaling company and gives risk-based judgement rather than hiding behind policy papers
• Lead through influence, aligning peers and stakeholders in fluent English and German
  
  

It's a plus if you:

• Know SME/B2B payments, credit or FX products
• Have oversight experience across multiple countries or MLRO structures
• Bring experience in fraud, ABC or sanctions evasion
• Are comfortable working with data (e.g. SQL, dashboards)
  
  

Think we're a good fit?

We’d love to hear from you! Send us your application by 20.11.2026 via our recruitment tool by clicking the APPLY button – but don’t wait too long as we will fill this role as soon as we find the right person.

Please note that only applications submitted via our recruitment tool will be considered. Applications received through any other channel (including email) will be immediately deleted and will not be reviewed.

You can read more about our recruitment process on our Careers page. If you want to learn more about the position, reach out to [email protected]

You'll get:

• 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 nice 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, 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
  
  

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.

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.