Head of AFC

Xapo seeks a Director to lead its first-line financial crime function, owning operational outcomes for Xapo Bank and Xapo VASP while ensuring regulatory compliance and operational efficiency.

This position serves as the accountable owner of Xapo’s first-line financial-crime operations, sitting at a Director level just below the MLRO and CRO. The role exists to allow second-line compliance leaders to focus on pure assurance by handing over the operational response to financial-crime risk across both regulated entities. The successful candidate will own the end-to-end process, making definitive judgments within Board-approved risk appetite bands and ensuring the function delivers measurable outcomes rather than simply processing queues.

Responsibilities

• Design, scale, and manage the complete first-line workflow for alerts, RFIs, onboarding reviews, screening, and monitoring across Xapo Bank and Xapo VASP.
• Maintain operations within Board-ratified risk appetite bands, making final decisions within those limits and escalating only by exception.
• Take full accountability for key AFC metrics, including open-alert volume, aging, manual review rates, automated clearance ratios, false positives, blocked payments, and iSAR timeliness and quality.
• Collaborate with the CFO to analyze the capital and cost-to-serve impact of the operation, treating financial efficiency and crime prevention as a unified balance sheet.
• Serve as the operational KYC/AML owner on the Growth and Payments Business Unit PGCs, directly managing the financial-crime rules that influence customer friction.
• Line-manage and develop AFC analysts, cross-training the team to eliminate single-person dependencies and prevent bottlenecks in decision-making.
• Optimize the manual-review model to reduce delays in customer approvals and prevent onboarding drop-offs, particularly during weekends.
• Integrate lessons from incidents and near-misses into first-line standards to prevent recurrence.
• Work with the CISO and AI teams to increase automated clearance rates and reduce false positives through governed models.
• Create essential business reporting on manual-review volumes, cost-to-serve, and remediation against appetite, providing stakeholders with clear, reconstructed-free data.

Requirements

• Substantial experience leading a first-line financial-crime operation within a regulated bank, fintech, or crypto institution.
• Proven operational leadership of the function, not just advisory experience.
• A clear track record of owning operational financial-crime metrics and demonstrably moving them toward target parameters.
• Deep competence in calibrating controls to actual risk, with an acute ability to avoid over-blocking or de-risking.
• Comfort discussing numbers, cost-to-serve, and capital impact with a CFO, treating financial efficiency as part of the risk balance.
• Professional credibility to evidence, explain, and defend the operating model and risk posture directly to regulators and the Board.
• Operational agility to work seamlessly across two distinct regulated entities (Bank and VASP) with separate regulatory frameworks.

What the company offers

• Work 100% remotely from anywhere in the world.
• Set your own work schedule and make use of a flexible PTO plan when you need to recharge.
• You’ll get a yearly budget for your individual learning and development goals.

About the company

Xapo prioritizes consumer protection and adheres to regulatory requirements by ensuring that all employees are accountable for upholding principles of fair treatment, transparency, and ethical conduct in their interactions with customers and stakeholders.

• Prioritizing consumer protection and regulatory adherence.
• Ensuring all employees are accountable for fair treatment, transparency, and ethical conduct.
• Fostering a culture of individual accountability in customer and stakeholder interactions.