Risk & Compliance Manager

• The Risk & Compliance Manager will be responsible for establishing, implementing, and overseeing Asan Pay’s enterprise risk management and compliance framework. The position will ensure that Asan Pay operates in accordance with Da Afghanistan Bank (DAB) regulations, EMI licensing requirements, AML/CFT requirements, KYC obligations, applicable laws, regulatory directives, and internal policies and procedures. The position will also support management in identifying and managing key risks and maintaining a strong culture of compliance, integrity, and risk awareness across the organization.

1. Risk Management

• Develop, implement, and maintain the Enterprise Risk Management (ERM) framework.

• Identify, assess, monitor, and report operational, financial, strategic, technology, liquidity, fraud, compliance, and reputational risks.

• Maintain the corporate Risk Register and monitor risk mitigation plans.

• Conduct periodic risk assessments across business units and key processes.

• Establish and monitor Key Risk Indicators (KRIs).

• Promote a strong risk-aware culture throughout the organization.

2. Regulatory Compliance

• Ensure compliance with DAB regulations, EMI licensing requirements, applicable laws, and regulatory directives.

• Develop and maintain compliance policies, procedures, and internal controls.

• Monitor compliance with regulatory and internal requirements.

• Coordinate regulatory reporting and compliance reviews.

• Monitor regulatory changes and assess their impact on Asan Pay.

• Act as a key focal point for regulatory compliance matters.

3. AML/CFT & KYC

• Develop and oversee the implementation of AML/CFT and KYC policies and procedures.

• Ensure appropriate customer and agent due diligence processes.

• Monitor transactions and identify suspicious activities.

• Ensure timely escalation and reporting of suspicious transactions to the relevant authorities.

• Oversee sanctions and watchlist screening.

• Support transaction monitoring and financial crime risk management.

• Coordinate AML/CFT and KYC training and awareness programs.

4. Fraud Risk Management

• Develop and maintain fraud risk management controls.

• Identify emerging fraud risks across wallets, transactions, agents, merchants, and digital channels.

• Coordinate with relevant departments to investigate and mitigate suspected fraud.

• Monitor fraud trends and recommend preventive measures.

5. Internal Controls

• Design, review, and evaluate internal control systems.

• Conduct compliance monitoring and control testing.

• Identify control weaknesses and recommend corrective actions.

• Monitor implementation of corrective action plans.

• Coordinate with Internal Audit and relevant departments where required.

6. Risk & Compliance Reporting

• Prepare periodic risk and compliance reports for Executive Management and the Board.

• Report significant risk exposures, compliance breaches, control weaknesses, and emerging risks.

• Develop dashboards and KRIs to support management decision-making.

• Ensure timely escalation of significant compliance and risk issues.

7. Policy & Procedure Development

• Develop, review, and update policies relating to:

o Risk Management

o Regulatory Compliance

o AML/CFT

o KYC

o Fraud Prevention

o Internal Controls

o Operational Risk

o Business Continuity

• Ensure policies remain aligned with applicable regulations and recognized industry practices.

8. Training & Awareness

• Conduct risk, compliance, AML/CFT, and KYC training for employees, agents, and relevant stakeholders.

• Promote awareness of regulatory obligations and ethical business practices.

• Support departments in implementing effective risk and compliance controls.

Education

• Bachelor’s degree in Finance, Banking, Accounting, Business Administration, Economics, Risk Management, or a related field.

• Master’s degree or relevant professional certification is an advantage.

• Professional certifications such as CAMS, CISA, CRMA, CIA, FRM, or equivalent are an advantage.

Experience

• Minimum 5 years of relevant professional experience in banking, Electronic Money Institutions (EMIs), fintech, financial services, risk management, compliance, AML/CFT, or internal audit.

• Experience with financial-sector regulatory requirements, risk management, compliance frameworks, and corporate governance.

• Experience in an EMI, payment institution, bank, or fintech environment is highly desirable.

Core Competencies

• Enterprise Risk Management

• Regulatory Compliance

• AML/CFT & KYC

• Fraud Risk Management

• Internal Controls

• Corporate Governance

• Risk Assessment & Analysis

• Regulatory Reporting

• Policy & Procedure Development

• Compliance Monitoring

• Strong Analytical & Problem-Solving Skills

• Excellent Report Writing & Presentation Skills

• Strong Communication & Stakeholder Management

• High Integrity, Ethics & Confidentiality

• Strategic Thinking

Languages

• Fluency in English

• Dari and Pashto highly desirable

Job Location:

Kabul-Afghanistan

AfghanPAY Services Company is building a community of young professionals who have the expertise and potential to excel within our business lines. We require potential candidates to submit their cover letter and CV to hr@asan-pay.afPlease include the vacancy number (ASANPAY-2026-004) and your field of expertise in the subject line of your email. We are committed to our nation’s future, fostering a culture of excellence, and welcoming those who share our vision

Please note: only short-listed candidates are contacted. 

Submission Email:

TO: hr@asan-pay.af