Responsable Conformité et LCB-FT

Context

• We are currently operating approximately 30k business accounts under a BaaS model

• The role of Financial Services in Pennylane’s strategy is set to grow, both in terms of revenue and product contribution, to serve our 750k+ current customer base

• As such, we are initiating a process to get licensed as Etablissement de paiement et Société de financement to meet our current functional scope at the very least

• Our ambition is to start onboarding new customers by early 2027 before starting migrating existing customers

• To meet this ambition, we are starting to hire our Tech, Product, Compliance and Ops leaders

• We are looking for a Lead Compliance / MLRO.

• Reporting directly to the Director of Compliance and Risk, you will be responsible for the consistency and effectiveness of the non‑compliance risk management framework across the payment institution and financing company. The role covers all regulatory compliance functions, including AML/CFT, customer protection, fraud management, in full alignment with French and European regulatory requirements.

• Your mission would be to:

  • Design and implement the compliance framework, risk, permanent controls for a combined payment services and financing perimeter.

  • Act as point of contact for the regulator on LCB‑FT / Tracfin matters

  • Build and lead a compliance team

  • Work in close partnership with the group compliance function (eg on GDPR and ethics), while maintaining full independence as a control function.

Missions & Objectives

A greenfield project with high autonomy and responsibility, direct exposure to regulators, and the opportunity to shape the compliance function and culture of a fast‑growing fintech with a robust preexisting customer base.

AML/CFT Program (MLRO)

• Act as the designated MLRO, responsible for filing Suspicious Activity Reports (SARs) with TRACFIN

• Oversee KYC/KYB procedures, risk scoring, transaction monitoring, and sanctions / PEP screening

• Chair the AML/CFT Committee and report to the Board on money laundering and terrorist financing exposure

• Keep the AML/CFT framework up to date in line with AMLD6, EBA guidelines, and ACPR requirements

Norms, Policies & Procedures

• Design, implement, and maintain compliance policies and procedures, including the AML/CFT procedure, the compliance manual, and all related internal frameworks

• Ensure procedures are accessible, up to date, and effectively communicated across the organization

New Product Compliance

• Review and formally approve all new products before commercialization, as well as any significant changes to existing products (including through M&A)

• Issue written, formalized opinions to ensure products are compliant with applicable regulations prior to launch

Non‑Compliance Risk Mapping

• Build, maintain, and update the non‑compliance risk map, which is distinct from the operational risk map but follows a similar process‑based identification methodology

• Ensure the map highlights key criminal and reputational risks

• Produce a synthetic, executive‑level view of the risk map for reporting to governance bodies (Board, Audit Committee, Risk Committee)

Permanent Compliance Control

• Lead the second‑level permanent control activities related to compliance, as part of the broader second‑level control framework

• Ensure that first‑level controls exist, are operational, and are effective

Compliance Systems & Tools Ownership

• Act as business owner for all compliance‑related systems, in particular AML/CFT transaction monitoring and alerting tools

• Define functional requirements for these tools and validate that delivered or updated systems are correctly configured and meet compliance expectations

• Ensure that any new business application or material change to an existing one remains compliant with regulatory obligations

Training & Advisory

• Design and deliver compliance training programs to raise awareness of non‑compliance risks across all business functions

• Provide guidance and advisory support to employees on compliance matters

Regulatory Watch

• Monitor and analyze regulatory developments applicable to the business (laws, regulations, guidelines, industry standards)

• Disseminate relevant regulatory updates across the organization in a timely and actionable manner

Governance & Reporting

• Collaboration with the Lead Control and Risk Officer

• Management reporting to the Director of Compliance & Risk and the Supervisory Board

• Training for local AML/CFT and Sanctions program

• Product counsel collaboration to ensure AML/CFT compliance for new products

Team Leadership

• Structure & recruitment, including team with SAR, TM, KYC, compliance operations specialists

• Performance management with KPIs

• Culture of excellence with ownership, honesty, accountability, documentation, and auditability for ACPR inspections

Experience

• 8 to 10+ years of experience in regulatory compliance, with significant exposure to a payment institution, bank, credit institution, or regulated fintech

• Proven track record as MLRO or designated AML/CFT officer

• Strong knowledge of the regulatory framework applicable to payment institutions and financing companies (PSD2, PSD3, DORA, AMLD, ACPR regulations)

Technical Skills

• Deep expertise in AML/CFT frameworks (KYC/KYB, transaction monitoring, sanctions screening)

• Experience as business owner for compliance tools and ability to bridge compliance requirements with IT/product teams

• Ability to read, interpret, and apply complex regulatory texts in both French and English

• Ability and passion to build from scratch: frameworks, policies, processes, tools, reporting

Soft Skills

• Strong leadership and ability to influence

• Excellent communication skills across all levels (Board, regulators, operational teams)

• Rigorous, principled, and accountable

• Pragmatic, impact‑driven approach, capable of operating under strong regulatory constraints without blocking innovation

• Comfortable operating in a dual posture of control and advisory, with clear boundaries between the two

• Strong pedagogy: able to explain complex regulatory topics to product managers, engineers and founders in simple, actionable terms

• Challenging yet constructive: comfortable questioning senior leaders, while remaining solution‑oriented and business‑minded

Languages, Presence & Location

• Languages: fluent French and English are mandatory

• Location: Based in France, with a strong preference for Paris. Regular on‑site presence expected; partial remote possible but not fully remote

Benefits

• Competitive compensation package, including equity components aligned with impact and responsibility

• 25 vacation days paid by Pennylane

• Company shares to enjoy a piece of the success story

• Budget to improve home workspace and monthly allowance to work from a coworking space when desired

• Access to fitness and wellness activities through partner Gymlib

• Latest Apple equipment provided

• Remote options within Europe within two hours difference from CET for certain roles

• Regular company events such as Tech Days and annual seminars

• French employees: French contract, 6 to 12 RTT, 5 weeks PTOs, lunch credits, healthcare cover, and events in Lyon, Bordeaux, Nantes

Equal Employment Opportunity

We are committed to providing an equal employment opportunity regardless of gender, sexual orientation, origin, disabilities, or any other traits that make you who you are. We fully embrace diversity, equity and inclusion and work to create a safe and inclusive environment.