AML/CTF Compliance Officer (MLRO), Australia

**Location:** Australia resident (Sydney or Melbourne preferred; other AU cities considered) · Full-time · remote-within-AU OK **Entity:** HitPay Payment Solutions Pty Ltd — AUSTRAC remittance reporting entity (IND100852288-001) **Parent:** HitPay Payment Solutions Pte Ltd (Singapore) **Reports to:** Group Head of Compliance (Kok Pin Ong from Oct 2026) for oversight; you are the **AUSTRAC-designated AML/CTF compliance officer** for the Pty Ltd (group HoC is not the AU named officer) **Level:** Mid-career named **AML/CTF Compliance Officer (MLRO)** — not a group CCO / Head of Compliance seat

## About HitPay

HitPay is a full-stack payments platform for SMEs. In Australia we operate through **HitPay Payment Solutions Pty Ltd**, enrolled with **AUSTRAC as a remittance service provider / reporting entity** (IND100852288-001). Group licences also include MAS MPI (Singapore), BNM (Malaysia), BSP (Philippines), FinCEN MSB (US), and DIA FSP (New Zealand). Compliance is lean and AI-assisted: automation does first-pass work; humans own the decisions that matter.

## The role

You will be designated as the **AML/CTF compliance officer** for HitPay Payment Solutions Pty Ltd under the AML/CTF Act **s26J** (and related Rules) — the AUSTRAC-facing named officer for our Australian remittance reporting entity. Market search title is often **MLRO**; Enrolment and AUSTRAC paperwork use **AML/CTF compliance officer** — this role is both.

You own the AU AML/CTF program day-to-day: CDD/EDD, monitoring escalations, SMR judgment and filings, AUSTRAC Online / enrolment / ABPF hygiene, training, and management reporting. You report into group Head of Compliance for oversight and consistency with other licences — but **you** are the AU named officer of record for the Pty Ltd, not a deputy doing paperwork for someone else in Australia.

**Australia residency is a hard statutory gate** under s26J(3) where designated services are provided at or through an Australian permanent establishment. Overseas remote is not viable for the named seat. Sydney/Melbourne preferred; other Australian cities are considered.

This is a **mid-career second-line seat**: hands-on financial crime / AML program ownership in payments, remittance, MSB-equivalent, or fintech — ready to be named — not a junior TM analyst, and not an ultra-senior Chief Compliance / empire-building CCO role. AFSL/ACL experience is not required for this remittance RE seat.

## What you’ll own

**AML/CTF program (Australia)** - Maintain HitPay Australia’s AML/CTF program against the AML/CTF Act and AUSTRAC Rules: CDD/EDD, ongoing CDD, monitoring standards, record-keeping, tipping-off, and staff training. - Keep AU policies and procedures current; close gaps before an examination finds them. - Advise Product, Ops, and Sales on AU-specific ML/TF risk for new products, corridors, partners, and customer types.

**Named officer / SMRs** - Single escalation point for suspicion from Ops / Financial Crime; evaluate internal escalations. - Final determination on Suspicious Matter Reports (and other AUSTRAC reports as applicable) with documented rationale — including reasoned decisions not to file. - Independence to escalate to Group Head of Compliance / CEO / board when needed.

**AUSTRAC relationship, enrolment & ABPF** - Day-to-day AUSTRAC engagement for the AU entity: correspondence, RFIs, examinations, and the reporting calendar (including annual compliance reporting and IFTI/TTR as applicable). - Own **AUSTRAC Online enrolment / ABPF hygiene** for HitPay Payment Solutions Pty Ltd (officer details, material changes, information requests) — not only SMRs and exams. - Support fit-and-proper documentation, including a **National Police Certificate / NPHC or foreign equivalent issued within 6 months** for Enrolment update. - Keep Australia permanently examination-ready.

**Group coordination** - Solid-line oversight from Group Head of Compliance; align AU standards with group frameworks without owning other jurisdictions’ licences as primary.

## What you’ll bring (must-have)

- **Australia resident** (hard statutory gate under s26J(3) if AU permanent establishment — stronger than work rights alone). - **4–8 years** (approx.) hands-on AML/CTF in **remittance, payments, fintech, or MSB-equivalent** — not only bank retail KYC ops. - Willing to be the **named AML/CTF compliance officer on AUSTRAC Enrolment** for HitPay Payment Solutions Pty Ltd and to provide a **National Police Certificate / NPHC or foreign equivalent issued within 6 months** for fit-and-proper / ABPF update. - Hands-on **SMR (or STR) drafting and decisioning** — can defend file-or-not in writing. - Working knowledge of the **AML/CTF Act**, AUSTRAC Rules/guidance, and AU typologies (scams, mules, remittance misuse). - Management-level authority in practice: escalate, influence product/ops, report to management/board. - Clear written judgment; documentation-first habit. - Existing right to work in Australia.

## Nice to have

- Prior named MLRO / AML CO on an AUSTRAC remittance or payments reporting entity. - Prior **AUSTRAC RFI / enrolment remediation** experience. - Remittance corridors / cross-border / PayTo-adjacent familiarity. - CAMS or AU equivalent. - Sanctions/screening tooling; TM calibration with ops/eng. - Exposure to multi-entity group models (reporting into regional HoC).

## Hard skips

- Not (and will not be) an Australia resident / no path to AU residency for designation. - Unwilling to be **named on Enrolment** or to complete **police-check / fit-and-proper** process. - Pure policy/advisory only — never filed SMRs or run an RE program. - Pure first-line TM / investigator IC with no program or filing ownership. - Only unrelated-sector AML with no payments/remittance transferability. - Demands CCO / board seat / “build a 20-person org” for this mid-career named-officer seat. - Treating AFSL Responsible Manager / ACL credit as the core of the seat (out of scope unless product expands).

## Interview

Founder + compliance screen → AML/AUSTRAC case discussion (program + SMR judgment + fit-and-proper) → offer.