Compliance Manager, Fraud Oversight

Fraud Oversight Manager

Pay Pal (Europe) S.à r.l. et Cie, S.C.A. ("PPEU") is a CSSF-supervised credit institution operating across Europe. As part of strengthening its fraud risk governance framework, PPEU is establishing a dedicated second-line fraud oversight capability within the Compliance function. The Fraud Oversight Manager will be responsible for independent oversight, challenge, and governance of fraud risk across PPEU, ensuring that fraud risk is managed in line with EU regulatory expectations, the Bank's risk appetite, and the Three Lines of Defence model.

This role operates within a highly outsourced and intragroup operating model and focuses on oversight of first-line and group-executed fraud activities, rather than ownership or execution of fraud controls.

Essential Responsibilities:

• Define compliance program strategy and priorities for the functional area, ensuring alignment with regulatory obligations and business objectives
• Oversee compliance monitoring, testing, and assessment activities to identify risks and ensure effectiveness of controls
• Lead complex compliance projects and initiatives, collaborating with business partners, legal, audit, and other stakeholders
• Establish best practices and frameworks for compliance risk assessment, control design, and program management
• Partner with business leaders to integrate compliance requirements into operations, products, and strategic initiatives
• Prepare and present compliance reports to business or cross-functional stakeholders, clearly communicating risk landscape, program effectiveness, and recommendations
• Manage regulatory examinations and audit activities, coordinating responses and ensuring timely resolution of findings

Minimum Qualifications:

• 5+ years of relevant compliance experience and a Bachelor's degree OR any equivalent combination of education and experience
• Demonstrated ability to lead and influence others in a compliance or regulatory context

Additional Responsibilities &

Preferred Qualifications:

Role Purpose

The Fraud Oversight Manager is responsible for:

• Providing independent oversight and challenge of fraud risk management
• Ensuring fraud risk is governed in line with regulatory expectations and internal policies
• Overseeing the Bank's reliance on group-operated fraud capabilities
• Supporting credible and consistent regulatory engagement on fraud-related matters

Key Responsibilities

• Fraud Risk Oversight and Compliance Framework
• Maintain and oversee the EU Fraud Oversight Policy, ensuring alignment with:
• CSSF / ECB expectations
• PSD2 and SCA requirements
• Internal governance standards
• Provide independent assessment of whether the Bank's fraud oversight framework is:
• proportionate
• effective
• aligned to its operating model
• Ensure fraud risk is appropriately reflected within the Bank's compliance and conduct risk framework
• Independent Challenge of First-Line Fraud Management
• Review and challenge first-line fraud risk management, including:
• fraud trends and drivers
• material incidents
• mitigation actions and control effectiveness
• Assess whether first-line outputs are:
• consistent with regulatory expectations
• aligned to risk appetite
• Provide independent opinions and escalate where:
• risks are not adequately managed
• explanations are insufficient
• Maintain clear separation from first-line ownership and execution
• Fraud Oversight Governance
• Lead the second-line oversight function within the Fraud Oversight Forum, ensuring:
• effective challenge
• structured escalation
• clear governance outputs
• Ensure the Forum operates in line with its Terms of Reference and regulatory expectations
• Provide second-line reporting and escalation into:
• Operational, Risk and Compliance Committee (OCRC)
• Authorized Management
• Oversight of Group-Operated Fraud Capabilities
• Provide second-line oversight of the Bank's reliance on group-operated fraud execution and controls
• Assess whether:
• the Bank is sufficiently informed of relevant changes
• fraud controls remain aligned with EU regulatory expectations
• Review material developments (e.g. changes, incidents, emerging risks) from an EU perspective
• Escalate concerns where group-operated capabilities may create:
• regulatory risk
• customer impact risk
• misalignment with EU expectations
• Fraud Risk Appetite and Escalation Oversight
• Ensure fraud risk is monitored and escalated in line with the Bank's risk appetite framework
• Provide independent challenge on:
• breaches or emerging risks
• appropriateness of escalation decisions
• Work with the Risk function to ensure fraud risk is:
• appropriately captured
• consistently assessed
• Regulatory Engagement and Supervisory Oversight
• Support and oversee fraud-related regulatory engagement, including:
• responses to supervisory queries
• thematic reviews
• fraud reporting discussions
• Ensure responses are:
• consistent
• complete
• aligned with regulatory expectations
• Oversee governance of group support for regulatory requests, including escalation where:
• responses are delayed
• data or analysis is insufficient
• Oversight of Fraud Management Information
• Assess the adequacy and appropriateness of fraud…