Risk Director

Risk Director

Department: Compliance

Employment Type: Permanent - Full Time

Location: London

Reporting To: Sara Cass

The Risk Director is responsible for the design, ownership, and effective operation of the firm's enterprise-wide risk management framework. The role provides independent second-line oversight of all material non-financial and financial risks arising from the firm's electronic money issuance, payment services, and foreign exchange trading activities.

Regulatory compliance, regulatory interpretation, and day-to-day compliance monitoring are owned by the Compliance Director. The Risk Director works in close coordination with the Compliance Director to ensure alignment between risk appetite, regulatory expectations, and the firm's overall control environment, without duplication or conflict of accountability. A group entity will be applying for a MiFID licence in 2026, and this role will support the project and assume MiFID entity risk responsibilities when operational.

• Own and maintain the Enterprise Risk Management (ERM) framework, ensuring it remains proportionate to the firm's business model, scale, and complexity.
• Define and embed the firm's risk appetite, tolerances, and escalation thresholds, subject to Board approval.
• Ensure consistent risk identification, assessment, mitigation, and monitoring across all business activities, including payments and FX trading.
• Maintain the firm-wide risk register and oversee the operation of risk assessment methodologies.
• Provide independent oversight of risks arising from FX trading activity, including market risk, liquidity risk, settlement risk, and counter party exposure.
• Review and challenge treasury, hedging, and liquidity management arrangements, including stress testing and scenario analysis.
• Oversee prudential and financial resilience risks relevant to Electronic Money Institutions (EMIs), including capital adequacy, safeguarding risk, and wind-down planning, in coordination with Finance.
• Oversee the firm's operational risk framework, including outsourcing and third-party risk, ICT risk, cyber resilience, fraud risk, and business continuity planning.
• Review material incidents and near misses, ensuring root cause analysis and remediation actions are implemented and tracked.
• Provide risk oversight of payment processing infrastructure, FX execution platforms, and critical systems.
• Assess and monitor conduct and reputational risks arising from products, customer journeys, pricing structures, and FX execution practices.
• Support the embedding of a strong risk culture consistent with FCA principles, Consumer Duty, and Treating Customers Fairly outcomes.
• Provide risk input into product governance and new business initiatives, distinct from compliance approval.
• Provide clear, independent risk reporting for the Executive Committee, Board, and Audit & Risk Committee, including emerging risks, risk appetite breaches, and stress scenarios.
• Offer effective challenge to senior management on strategic decisions, growth initiatives, and material business changes.
• Lead risk input into new product approvals, outsourcing decisions, and material change assessments.
• Act as the senior management contact for risk-related FCA matters, supervisory reviews, and thematic work, while deferring regulatory interpretation and compliance policy matters to the Compliance Director.
• Support regulatory submissions and reviews by providing risk assessments, scenario analysis, and management information, without assuming ownership of compliance obligations.
• Lead and develop the Risk function, ensuring appropriate capability, independence, and resourcing.
• Promote risk awareness and accountability across first-line business functions.
• Work collaboratively with the Compliance Director, Finance Director, MLRO, and other Senior Managers to maintain a coherent and effective second-line framework.
• Line manage two team members in line with company values.

The Risk Director retains ownership of the firm's risk framework and oversight activities but is not responsible for:

• Regulatory interpretation or ownership of FCA rules.
• Day-to-day compliance monitoring, testing, or advisory activity.
• Regulatory policy drafting or maintenance.
• AML/CTF or sanctions compliance (owned by the MLRO and Compliance Director).

These responsibilities sit with the Compliance Director and MLRO, with the Risk Director retaining oversight of the risk impact of regulatory and financial crime issues.