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Head of AML (f/m/x)

RemoteGermany, Berlin, BerlinBusiness - Legal

Job description

About lemon.markets 🍋

We're on a mission to open 100 million brokerage accounts within the next ten years. Building the infrastructure for FinTech companies to launch an investing feature or product in Europe. Delivering the full value chain of brokerage through one API.

Over the last quarters, we focused on bringing the first version of the API to the market. Thousands of developers signed up and hundreds started to build their individual use cases with us. This resulted in 80+ inquiries from companies to launch their own stock trading UI with lemon.markets. With 15 million of fresh funding, we are now taking the next steps toward our mission: Building out our capabilities to allow (Fin)Tech companies to offer investment opportunities to their customers.

We have experienced first hand that brokerage infrastructure is broken. It’s a messy and complex problem that will take time to solve. But that’s exactly what we enjoy. Going to places nobody else dares and shielding our customers from the biggest pain. This not only creates tons of value when done right, but attracts the smartest minds - because we believe outlier companies are built by exceptional people like you.


Your Mission:

As Head of AML and KYC Operations you will be the first in your role, tasked with building the foundations of the Anti-Financial Crime (AFC) department within lemon.markets. You will implement and execute the full scope of AFC related processes — whether they concern anti-money-laundering (AML), counter financing of terror (CFT), sanctions, know-your-customer (KYC) or other criminal acts, such as e.g. fraud. With that, you will play an important part in the development & launch of our brokerage API for companies.

At lemon.markets ownership is a key principle. Meaning you will have a lot of autonomy in shaping your area of responsibility. Reporting to our back-office managing director, and working with a team of tech, legal and regulatory professionals, this role will offer you the exciting opportunity to build a team from the ground up over the years to come. Leverage on your previous experiences and help us build the future of embedded brokerage!


You will:

  • Act as the Money Laundering Reporting Officer (MLRO) under section 7 of the GwG and as central office for the coordination of all AFC related measures.
  • Draft and continuously update an institution-specific risk analysis within the meaning of § 5 GwG.
  • Develop and continuously update internal policies and procedures, as well as appropriate business and customer-related systems & controls for the prevention of money laundering, terrorist financing and other criminal acts.
  • Design a flawless & automated KYC process that meets all legal requirements and delights our customers and partners, if necessary with the support of external service providers.
  • Analyse all unusual facts and transactions (suspicious cases) and, if required, report them to the FIU.
  • Monitor transactions, classify customers into risk categories (which you define) and implement a reliable KYC process.
  • Independently monitor legal developments in the AFC sector and inform staff and leadership as necessary and/or appropriate.
  • Participate in new product processes and help to think through relevant features end to end.
  • Regularly train employees and leadership team on all AFC matters.
  • Act as first point of contact for supervisory authorities, law enforcement agencies, the FIU and both internal and external auditors on all AFC related matters.

Job requirements

You will be successful in this role if:

  • You have several years of professional experience in AFC, particularly AML and KYC matters in the financial industry towards consumers — ideally in a securities firm.
  • You have been previous holding the role of MLRO or deputy MLRO in a regulated company
  • You have gained deep knowledge of German and EU financial market regulation and relevant processes with regard to topics such as e.g. KYC, risk analysis, transaction monitoring, fraud / terrorist financing, sanctions / embargo.
  • You have relevant experience in modelling and exercising KYC and AML related control measures as well as in drafting and implementing organizational documents within the meaning of section AT 5 of MaRisk.
  • You stay on top of things! You are well versed in working in high paced environments, independently completing tasks and fulfilling documentation requirements in a time-sensitive environment with competing priorities.
  • “This is not my job!” is not part of your vocabulary - you are intrinsically motivated to deliver value for our customers by taking initiative and challenging the status quo, even if this means admitting one's own shortcomings and changing things.
  • You're able to apply complex regulatory frameworks to real life scenarios in a tech driven environment — this isn't always easy and will require you to think outside the box!
  • You can prioritize effectively and are able to sift through the noise and assess what's critical for the current priority.
  • You are keen to take on responsibility. Prior experience with leadership and people management will give you a head start, but is not mandatory.
  • You speak both German and English business fluent & you are confident to speak with internal and external stakeholders in both languages.


How we take care of you:

🚀 Competitive compensation package:

We will offer you a mix of cash and stock options based on your appetite for upside.

💎 Make a real impact:

Shape the employee experience of all lemoneers. Decide on tools and processes, to make working at lemon.markets a great experience.

🕑 Flexible working hours:

We value focus time. Encouraging everyone to minimise fixed meetings and leverage asynchronous communication.

💻 Build your perfect setup:

Mac, Mechanical Keyboard, Screen. These are not expenses but investments. Please tell us what is needed to make you productive, and we will take care of it.

🏢 Onsite first, but remote flexible:

We all believe that personal collaboration is an integral part of working together, but offer flexibility for remote working. Once a quarter the whole team meets for our offsite to hone this belief. In case you want to relocate to Berlin, we can provide assistance and visa sponsorship.

📈 Grow with us:

We take your personal development seriously, meaning that we make sure to constantly mentor and challenge you so that you can reach your next level and beyond. Of course, we also cover the costs for the mandatory training of MLROs.

👶🏽 Get the flexibility you need:

Whether you have a family or a passion that you want to follow on the side. We want to offer you a setting that fits your current stage in life.


As an equal opportunity employer, lemon.markets is committed to building an inclusive workplace. The company welcomes people from all different backgrounds, including age, citizenship, ethnic and racial origins, gender identities, individuals with disabilities, marital status, religions and ideologies, and sexual orientations to apply.


About the process

Hiring can be an exhausting process, especially when you're the one trying to get hired. Therefore, we try to make this a fast and transparent process. Additionally, you will always have one contact person guiding you through the process and helping you to schedule meetings, and setting you up on a path of success. Your process will look like this:

  1. Get to know each other - Teresa - Chief of Staff | 45 minutes
  2. All things AML - Andreas - General Counsel | 60 minutes
  3. Brokerage Deep Dive - Markus - MD | 60 minutes
  4. Meet the lemoneers at our HQ
    1. Meet the Brokerage team | 60 minutes
    2. Meet the Founder | 45 minutes
    3. Ask us anything with the team | 45 minutes

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