POSITION SUMMARY
The Merchant Review Team Lead is a senior role within the Risk Monitoring department, responsible for leading the team that manages the end-to-end merchant CDD/EDD review lifecycle and AML/CFT compliance monitoring across the acquiring portfolio. The Lead oversees the quality and timeliness of all merchants due diligence reviews, drives process improvements, manages team workload and KPIs, and serves as the primary escalation point for complex compliance and risk cases. The role also carries responsibility for periodic processing activity oversight and merchant change request governance, ensuring the bank's merchant portfolio remains compliant, well-documented, and appropriately risk-rated at all times.
KEY RESPONSIBILITIES
Team Leadership and Operations
- Lead, manage, team of merchant review analysts, setting clear priorities, workload allocation, and quality standards.
- Monitor team KPIs including: pending CDD/EDD review volumes, aged backlog reduction targets, documentation completion rates, change request turnaround times, and escalation rates.
- Conduct regular 1:1s, performance reviews, and coaching sessions to develop analyst capability and ensure consistent application of policy.
- Design and maintain SOPs and working procedures for merchant review workflows, ensuring the team operates to a consistent and audit-ready standard.
- Report team performance, portfolio risk trends, and escalation outcomes to the Head of Risk on a regular basis.
- Act as the primary escalation point within the team for complex cases, high-risk merchants, PEP/sanctions matches, and material change requests.
Merchant Due Diligence & AML Compliance Oversight
- Oversee the team's execution of CDD and EDD reviews across the merchant portfolio, ensuring reviews are prioritised and completed according to the merchant's risk tier and system-generated risk score.
- Review and sign off on complex or high-risk CDD/EDD cases, including those involving complex ownership structures, offshore entities, politically exposed persons, and adverse media findings.
- Ensure PEP and sanctions screening is conducted on all merchant principals, UBOs, directors, and associated parties; manage escalation of matches per policy and regulatory obligation.
- Validate that all required documentation is in place — proof of identity (POI), proof of address, certificate of incorporation, UBO declarations, source of funds, business licenses, and any additional requirements based on the merchant's risk classification.
- Own the process for chasing outstanding merchant documentation, ensuring the team actively reduces the pending review backlog and no merchant remains unreviewed beyond policy-mandated timeframes.
- Oversee EDD processes for high-risk merchants, ensuring enhanced scrutiny is consistently applied and findings are well-documented and defensible under regulatory scrutiny.
- Maintain oversight of adverse media screening processes and ensure material findings are assessed, escalated, and recorded appropriately.
- Ensure the merchant risk scoring system outputs are regularly reviewed and that risk tier assignments accurately reflect current merchant profiles; escalate discrepancies or anomalies for reassessment.
Merchant Change Requests
- Govern the merchant change request process, ensuring all requests — including ownership and UBO changes, MCC additions, processing limit increases, settlement account amendments, website and business model changes, and legal entity restructuring, are assessed through the appropriate risk and compliance lens.
- Approve lower-risk change requests within delegated authority; escalate material changes for senior review or re-underwriting where warranted.
- Ensure that change requests triggering CDD/EDD re-review obligations are identified and actioned promptly and documented correctly.
- Coordinate with Compliance, Legal, and Relationship Management to ensure all changes are approved and implemented only once risk and compliance requirements are fully satisfied.
Stakeholder Engagement & Governance
- Serve as the subject matter expert on merchant due diligence and AML compliance monitoring in cross-functional meetings, internal audits, and regulatory examinations.
- Partner with the Compliance function and MLRO to ensure merchant review practices remain aligned with evolving AML/CFT regulatory requirements and internal policy updates.
- Contribute to risk committee reporting, providing portfolio-level insights on merchant risk trends, review backlog status, and escalation outcomes.
- Support internal and external audits by ensuring all team activities are documented to the required standard and readily accessible for review.
QUALIFICATIONS AND EXPERIENCE
Required
- 4+ years of experience in AML compliance, KYC/CDD operations, merchant acquiring risk, or financial crime within a regulated financial institution or payment processor.
- Demonstrated experience leading or supervising a team in a compliance, KYC, or risk monitoring function.
- Strong working knowledge of CDD/EDD requirements, UBO identification, PEP and sanctions screening, and adverse media review processes.
- Solid understanding of AML/CFT regulatory frameworks and their application to merchant acquiring.
- Knowledge of card scheme rules, chargeback thresholds, and fraud monitoring in an acquiring context.
- Strong written communication skills, able to produce clear escalation reports, policy documents, and management reporting.
KEY COMPETENCIES
- Strong leadership — able to motivate a team, manage performance, and drive results
- Sound judgment in complex escalation and risk-based decision making
- Highly organised with the ability to manage competing priorities and a high-volume review pipeline
- Detail-oriented with strong documentation discipline
- Proactive in driving the team to reduce backlogs and close cases to completion
- Effective communicator and collaborator across Compliance, Underwriting, Legal, and senior management
- Adaptable and resilient under regulatory deadlines and audit pressure
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