MLRO / Nominated Officer (AML/CFT)

Location: Fully remote (global)

Engagement: Independent Contractor, Part-Time (est. 10–20 hrs/week, flexible)
 

About empyrean.cash

We’re a Portugal-based fintech crypto-funded payment cards with a clean UX and pragmatic, risk-based compliance at the core. Distributed team, async-friendly.

The role

Own the AML/CFT framework as our part-time MLRO/Nominated Officer. You’ll be the confidential point for SAR/STR decisions, keep our crypto↔️fiat controls tight, and report independently to the founders/Board.

What you’ll do

Act as central point for SAR/STRs: triage, decisioning, documentation, and filings (as applicable).

Maintain a concise, risk-based AML/CFT program (EWRA, policies & procedures, CDD/EDD, sanctions/PEP screening, ongoing monitoring, recordkeeping).

Tune transaction-monitoring logic for card spend and on/off-ramp flows; run periodic QA/sampling.

Prepare quarterly MI/board updates; support audits/partner due-diligence questionnaires.

Deliver lightweight staff training and keep registers/attestations current.

Oversee AML vendors (KYC, screening, blockchain analytics, Travel Rule) and due-diligence.

What you’ll bring

1–3+ years in AML/CTF within crypto, payments/EMI, or fintech; hands-on SAR/STR experience.

Working knowledge of Portugal/EU AML (Law 83/2017, MiCA context) — Portuguese language helpful but not required.

Comfortable building pragmatic controls for a startup (not just policy writing).

Data-literate (Excel/SQL basics, alert review, sampling) and clear written communicator in English.

Nice-to-have: CAMS / ICA / CFCS or willingness to obtain.

Engagement details

Contractor arrangement (you invoice monthly; you’re responsible for your own taxes/registrations).

Flexible hours, async communication (Telegram), occasional calls across time zones.

Optional travel for team offsites or partner meetings.