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토스 · 토스 · AML ・ Compliance ・ Anti-Money Laundering ・ Brazil ・ Global

AML/CFT Manager (Gerente de PLD/FT, Toss Brazil)

#토스 채용

이 공고, 이렇게 물어볼 겁니다

Q1
브라질의 AML/CFT 규제를 따르는 데 있어 가장 중요한 요소는 무엇이라고 생각하시나요? 구체적으로, '이런 문제가 있었는데 제가 이렇게 해결했다'는 식으로 사례를 하나 꼽아서 말씀해주실 수 있을까요?
🎯 브라질의 AML/CFT 규제에 대한 이해와 문제 해결 능력 확인
Q2
트랜잭션 모니터링과 의심스러운 활동 보고를 어떻게 진행하시나요? 특히, 의심스러운 활동을 식별하고 보고하는 프로세스는 무엇인가요?
🎯 트랜잭션 모니터링과 의심스러운 활동 보고 능력 확인
Q3
제재 스크리닝을 어떻게 진행하시나요? 특히, UNSC 리스트와 OFAC 리스트를 사용하여 제재 대상자를 식별하는 방법은 무엇인가요?
🎯 제재 스크리닝 능력 확인
Q4
AML/CFT 프로그램의 성과를 어떻게 측정하시나요? 특히, 프로그램의 효과성을 평가하고 개선하는 방법은 무엇인가요?
🎯 AML/CFT 프로그램의 성과 측정 능력 확인
질문만 읽으면 컨닝이에요. 소리 내어 답해보세요 — 어디서 틀어지는지 짚어드립니다.

공고 내용

브라질 현지 근무 포지션입니다. This role is based in São Paulo , Brazil.

  • About the Team You’ll Join
  • ·

Toss is South Korea's leading financial super app, trusted by over 20 million users and backed by a fully licensed financial group. Guided by our mission to remove financial friction and redesign financial services from the ground up, Toss continues to transform the finance industry through innovation and simplicity.

  • ·

As we expand into Brazil, we operate a money transfer service in partnership with a licensed Brazilian payment institution. We are now looking for an AML/CFT Manager to lead and operate Toss Brazil's AML/CFT/CPF program.

  • About the Role
  • ·

The AML/CFT Manager will lead Toss Brazil's Anti-Money Laundering, Counter-Terrorist Financing and Counter-Proliferation Financing (AML/CFT/CPF) function, in accordance with Law No. 9,613/1998 (as amended by Law No. 12,683/2012), Law No. 13,260/2016, and the risk-based requirements of Circular BCB No. 3,978/2020.

  • ·

You will run our internal AML/CFT/CPF program end to end with operational independence, work closely with our licensed partner's compliance team on escalations, due diligence, and have direct access to senior management and to the global HQ AML organization.

  • What You'll Work On
  • AML Program Ownership
  • Own and maintain Toss Brazil's AML/CFT/CPF policies, procedures and internal controls, aligned with the licensed partner's program and Circular BCB No. 3,978/2020
  • Maintain the Internal Risk Assessment (Avaliação Interna de Risco) covering customers, products, services, distribution channels, IT system and operations
  • Ensure new products, services, channels, partners and material business changes are assessed for ML/TF/PF risk prior to implementation
  • Customer Due Diligence
  • Oversee KYC/CDD/EDD processes across the customer lifecycle, including PEP identification and enhanced measures for high-risk customers under Circular BCB No. 3,978/2020
  • Maintain the customer risk rating methodology and escalation workflows for high-risk cases
  • Transaction Monitoring Escalation
  • Operate transaction monitoring remittance flows; manage rules, thresholds and alert investigation workflows
  • Investigate suspicious activity and escalate reportable cases to the partner's compliance team with complete and timely case files
  • Maintain records in line with the retention obligations of Law No. 9,613/1998 and Circular BCB No. 3,978/2020 and the partner's record-keeping requirements
  • Sanctions Screening
  • Oversee sanctions screening against UNSC lists (subject to immediate asset-freezing obligations under Law No. 13,810/2019), OFAC, EU and other lists applicable under group standards
  • Maintain sanctions procedures and escalation paths: confirmed true matches result in immediate blocking and notification to the partner's compliance team
  • Partner Regulatory Alignment
  • Act as the primary AML/CFT/CPF counterpart to the licensed partner's compliance team: respond to KYP/KYS due diligence, periodic reviews and information requests
  • Monitor Brazilian regulatory developments (BCB, CMN, COAF) and ensure timely adaptation of internal controls
  • Governance Reporting
  • Report to senior management and global HQ on program performance, emerging risks and material AML/CFT/CPF matters requiring coordination or support
  • Oversee Know Your Employee (KYE) procedures for local staff, including screening at hiring and on an ongoing basis, in line with Circular BCB No. 3,978/2020
  • Design and deliver AML/CFT/CPF training for local staff
  • Support group-level internal reviews
  • What We’re Looking For
  • Must-Have
  • Based in Brazil with valid work authorization; professional working English
  • 8+ years of AML/CFT (PLD/FT) experience, with at least 3 years in a leadership or senior role within a financial institution, payment institution or fintech
  • Strong working knowledge of Law No. 9,613/1998, Circular BCB No. 3,978/2020 and COAF regulatory expectations
  • Hands-on experience with transaction monitoring, suspicious activity investigation and KYC/CDD/EDD operations
  • Independent judgment with the confidence to escalate or block without deference to commercial pressure
  • Strong communication skills, including partner-facing due diligence responses and senior-level reporting
  • Preferred
  • Experience in remittance, payments (instituição de pagamento) environment
  • Experience operating under a BaaS / white-label / sponsor arrangement, including responding to partner due diligence and audits
  • CAMS or a recognized Brazilian PLD/FT certification
  • Familiarity with PIX and instant-payment fraud and money laundering typologies
  • Working knowledge of the LGPD (Law No. 13,709/2018) as it applies to KYC data handling
  • Experience collaborating with a global HQ AML team in a multi-jurisdictional environment
  • Personal Attributes
  • High ownership mindset with strong prioritization and independent judgment
  • Demonstrated integrity, honesty, and soundness of judgment in prior roles
  • Clean regulatory and pro
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