Xinja Job description: Head of Financial Crime Compliance


Xinja is building an Australian, independent 100% digital bank designed entirely for mobile. We are building a business with our customers and designed in their interests. Neobanking will disrupt the existing banking model and create a whole new generation of experiences.

Now….let’s talk about you:

This role leads Xinja’s Financial Crime Compliance (FCC) function and has a reporting line to the Chief Risk Officer (CRO).

You will need to act with courage, impartiality, and without fear or favour to ensure Xinja has an appropriate risk framework that is effectively implemented across the organisation.

We expect the highest standards of ethical lending, banking and have zero tolerance for deliberate compliance or ethical breaches. This role should lead by example in this fashion and take whatever action is appropriate to ensure the rest of the business meets these standards.

We expect you to be proactive in seeking out failure to adhere to Xinja’s Risk Appetite Statement, Risk Management Strategy, other policies and ensuring the highest standards in our team.

This role is considered a Responsible Person position under APRA’s Fit & Proper regime and therefore must comply with Xinja’s Fit & Proper Policy. This role is also considered an Accountable Person position under the Commonwealth Government’s Banking Executive Accountability Regime (BEAR). An accountable person must take reasonable steps, that are systemic in nature, in conducting responsibilities to prevent matters from arising that would adversely affect the prudential standing or reputation of Xinja.


Xinja’s offices are in the Sydney CBD but we support flexible working.

Our 10 golden rules

To be successful at Xinja you are going to need to be happy working with our 10 golden rules.

  1. No dickheads… however good they may be. No dress code (but sometimes you need to look smart :-). No power trips because of a hierarchy. Intellect, customer experience and implementation is all that matters.
  2. Everything is in the cloud.
  3. We use real time data to evaluate our business and we reward staff on a quarterly basis with an entirely discretionary profit share. No one gets a share of the profit if our investors aren’t making money and our customers aren’t happy.
  4. We are here to make money, that’s why we exist, and we don’t screw people over to do it. We don’t lie to our clients in person or in marketing. We don’t engage in immoral lending; if our grandmother would think it was wrong, then it is. We aim to make lots of money ethically and we are proud of it.
  5. No one is entitled to work at Xinja. It is a huge honour to represent people’s hopes of a new bank and we earn that honour every day.
  6. We look after our people bloody well. We stand by them if they are in genuine need.
  7. We are truthful and direct with each other. Everyone says what they think in a robust, challenging, edgy environment. That means we won’t be the right place for everyone to work, and that’s ok.
  8. We only hire people better than us. We never, ever settle because we need a body. We do psychometric testing to get the best people, every time.
  9. About half our team, executive and board will be female, if they aren’t we aren’t recruiting the best people. We actively seek all types of diversity combined with brilliance.
  10. If you discriminate against someone because of who they love/sleep with, you’re a dickhead…please see rule 1.

Day to day, you’ll:

  • Provide FCC related input to reviews of the Risk Management Strategy and Risk Appetite Statement
  • Develop FCC risk management frameworks and policies covering:
    • Anti-money laundering;
    • Counter-terrorism financing;
    • Anti-bribery and corruption; and
    • Sanctions

  • Hold the role of Xinja’s Money Laundering Reporting Officer and manage Xinja’s relationship with AUSTRAC and other FCC relevant regulatory or enforcement bodies Monitoring adherence to the above frameworks and policies and reporting breaches of them.
  • Review and challenge the effectiveness of Line 1 in their identification and mitigation of FCC risks, to ensure they are appropriately identified and controlled and/or mitigated effectively.
  • Provide the CRO with Line 2 level assurance over the effectiveness of Line 1 in their identification and mitigation of risks.
  • Report material FCC incidents to the CRO and appropriate executive forums and provide challenge to Line 1 teams and management forums; and
  • Report material FCC breaches to the Chief Risk Officer, Chief Compliance Officer and relevant regulators.
  • Provide relevant regulatory attestations and declarations, as and when required, regarding the adequacy and effectiveness of FCC-related risk management systems and controls.
  • Ensure appropriate processes and tools are in place in order to assess and strengthen Xinja’s risk culture and promote the Code of Conduct and Xinja’s 10 Golden Rules.

You should apply if you:

  • Have 5 – 10 years experience working in FCC within a retail bank or remitter firm
  • Have experience working as part of a senior management team.
  • Have a deep understanding and knowledge of Australian Banking regulation and compliance requirements.
  • Have experience in developing and executing FCC policies.
  • Have excellent oral and written communication skills.
  • Have the ability to create and maintain positive business relationships.
  • Foster the delivery and adoption of new technologies to analyse and manage FCC
  • Are highly motivated and goal-oriented, with proven leadership qualities.
  • Have the ability to meet deadlines, make independent decisions and utilise sound judgement.
  • Demonstrate professionalism, integrity and trustworthiness.

Changing banking for good:  

Developing the best neobank in the country is an exciting and challenging task. Our ethos is based on a win-win with our customers; if they do well, so do we. We believe it’s time Australians had access to the kind of technology that just allows them to get a lot more out of their money, with less angst.  We are for profit and for purpose.

We extend that attitude to our people and our partners. We have an inclusive and diverse culture where we look after our staff and trust them with significant responsibility, but support them well. This is a great opportunity to be part of building a great company AND learn heaps along the way.

If you’re up for this:  

Please email your CV to [email protected]

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