About the Role
This role is initially structured as a consulting engagement. In addition to the responsibilities outlined below, the candidate will support the establishment of the initial operational infrastructure of Xsolla Payment Network EU B.V. It is intended that this engagement will transition into a permanent, full-time Head of Compliance position.
We are building an international payment business in the EU and are looking for an experienced Head of Compliance to join us at the ground level. This is a pivotal, hands-on role: your first and most critical mission will be to lead the full end-to-end process of obtaining a Payment Institution (PI) or Electronic Money Institution (EMI) license from De Nederlandsche Bank (DNB), including preparing all required documentation, managing the regulatory dialogue and steering the application to approval.
Once the license is secured and the business is live, you will own the ongoing compliance strategy, framework, and culture of the organisation.
Beyond the Netherlands, you'll be part of a wider team driving Xsolla's global licensing efforts, from MSO registration in Hong Kong to Money Transmitter Licenses across the US. This is a rare opportunity to build genuine cross-border regulatory expertise, working alongside colleagues navigating different regulators, legal frameworks, and market entry strategies, all in service of one connected payments network.
Payment License Application (Priority Focus)
Lead the complete PI/EMI license application process with DNB from initiation to approval, acting as the primary point of contact with the regulator throughout.
Prepare, compile, and submit all required application documentation, including the compliance programme, AML/CFT policies, governance structure, internal control frameworks, risk assessments, and business plan compliance sections.
Coordinate with legal, finance, operations, and external advisors to ensure all regulatory requirements are met ahead of submission.
Manage ongoing DNB and AFM correspondence, information requests, and supervisory interactions during and after the licensing process.
Compliance Framework & Strategy
Build the compliance function from the ground up, designing and implementing policies, procedures, controls, and training programmes suited to an EU-regulated payment institution.
Develop and maintain a strategic compliance framework aligned with applicable EU regulations, DNB/AFM supervisory expectations, and international best practices.
Define compliance objectives, KPIs, and governance structures to support the organisation as it scales post-launch.
Regulatory Monitoring & Risk Management
Monitor regulatory developments across the EU and the Netherlands, including updates to PSD2/PSD3, AMLD (6AMLD and beyond), MiCA where relevant, EBA guidelines, and DNB/AFM communications, assessing their impact on operations.
Conduct regular compliance risk assessments, internal audits, and gap analyses; oversee the remediation of identified issues.
Lead compliance investigations, incident management, and escalation processes, reporting findings to senior management as appropriate.
AML/CFT & Financial Crime
Design and implement a robust AML/CFT programme in line with the Wwft (Wet ter voorkoming van witwassen en financieren van terrorisme), EU Anti-Money Laundering Directives, and EBA guidelines.
Oversee KYC/CDD/EDD processes, transaction monitoring, sanctions screening, and suspicious transaction reporting (STR) to FIU-Nederland.
Stakeholder & Cross-functional Collaboration
Act as the primary compliance contact for DNB, AFM, FIU-Nederland, and other relevant authorities.
Partner closely with legal, risk, technology, product, and operations teams to embed compliance into business processes and new product development.
Represent the company in industry forums and relevant EU regulatory working groups.
Reporting & Governance
Prepare and submit all regulatory reports, filings, and periodic disclosures required under DNB/AFM supervision.
Maintain accurate compliance records and ensure transparency in all reporting obligations.
Education
Master’s degree in Law, Finance, Business Administration, or a related field.
Professional compliance certifications are a strong advantage (e.g., ICA Diploma in Compliance, CAMS, Certified Compliance Professional or equivalent EU-recognised qualifications).
Experience
Minimum 7 years of compliance experience within the payments, e-money, or financial services industry in the EU.
Demonstrated hands-on experience leading a successful PI or EMI license application with DNB or another EU national competent authority (e.g., BaFin, CBI, FCA pre-Brexit, Banca d'Italia) is essential - candidates without this experience will not be considered.
Proven track record of building compliance programmes from scratch within a regulated payment or fintech environment.
Experience managing regulatory relationships with DNB, AFM or equivalent EU supervisory bodies.
Regulatory Knowledge
Deep expertise in PSD2 (and awareness of PSD3 developments), AMLD, EBA Guidelines on outsourcing, internal governance, and ICT risk.
Strong working knowledge of Wwft, GDPR and applicable DNB/AFM supervisory frameworks.
Familiarity with EU sanctions regimes (EU/OFAC overlap), AML/CFT typologies in the payment sector and relevant EBA opinions.
Skills & Attributes
Fluency in English is required; Dutch is a strong advantage for DNB engagement.
Exceptional written and verbal communication skills, including the ability to produce clear, regulator-ready documentation.
Strong project management skills with the ability to drive a complex licensing process to completion under pressure.
High degree of integrity, professional discretion and comfort operating in an early-stage, fast-moving environment.
Collaborative mindset with the ability to work cross-functionally and influence stakeholders at all levels.
Why join us?
Join a global compliance team building payment licenses across multiple continents, from the EU to Asia to the Americas, gaining exposure few compliance careers offer.
Shape the compliance function of a new EU payment institution from day one.
Direct engagement with regulators and real ownership of a complex, high-impact licensing process.
Flexible/hybrid working arrangement based in the Netherlands.
