Senior Anti-Money Laundering (AML) Manager (m/f/d) /Geldwäschebeauftragter (m/w/d)


Company Description

SCAYLE Payments GmbH is a 100% subsidiary of ABOUT YOU Holding SE.
The GmbH is the in-house payment service provider of the ABOUT YOU Group. SCAYLE Payments GmbH, which is still under build-up, will take over the payment method control in the checkout of the ABOUT YOU marketplace as well as all deposit and withdrawal processes for end customers and merchants on the marketplace as part of the ABOUT YOU platform function.

Job Description

As a Senior Anti-Money Laundering (AML) Manager (m/f/d) (Geldwäschebeauftragter) of Scayle Payments GmbH you will be a member of Scayle Payments’s Compliance Team located in Hamburg. In your function as an appointed AML Officer (Geldwäschebeauftragter) of Scayle Payments, you will drive all aspects of the Anti-Money Laundering program of the obliged entity and make an impact with regard to the prevention of white-collar crime. Your direct reporting line will be the Managing Director of Scayle Payments.


  • Creation and regular updates of a risk analysis by determining and evaluating the risks of money laundering and terrorist financing associated with the nature and size of business activities Scayle Payments engages in. To pay particular attention to the risk factors specified in annexes 1 and 2 of German Money Laundering Act (Geldwäschegesetz – GwG) and to the information that is made available on the basis of the national risk assessment. 
  • The development of appropriate business and customer-related internal safeguards in order to manage and to reduce the risks of money laundering and terrorist financing in the form of principles, procedures and controls in relation to the Money Laundering Act (Geldwäschegesetz – GwG). Appropriate are measures that correspond to the respective risk situation of the obliged entity and that adequately cover it. The AML Compliance Officer must monitor the functionality of internal safeguards and update them if necessary. Internal Safeguards are in particular:  
    • Dealing with risks under section 6, para. 1 of GwG
    • The customer due diligence requirements under sections 10-17
    • Compliance with the reporting obligation under section 43 para. 1
    • Recording of information and retention of documents under section 8 and
    • Compliance with other provisions under anti-money laundering and counter terrorist financing law
  • The development and updating of appropriate measures to prevent the abuse of new products and technologies for committing money laundering and terrorist financing or for the purpose of promoting the anonymity of business relationships or transactions
  • Checking the reliability of employees by appropriate means, in particular via systems of the obliged entity for controlling and appraising the staff
  • Initial and ongoing training of employees with regard to the typologies and current methods of money laundering and terrorist financing and on the provisions and obligations relevant in this regard, including rules for data protection
  • Ensuring the review of the above-mentioned principles and procedures in an independent inspection where such a review is appropriate given the nature and size of the business.
  • Furthermore, to make arrangements appropriate to the nature and size of the obliged entity to enable the employees and persons in a comparable position to report contraventions of provisions under anti-money laundering regulations to appropriate bodies while ensuring that their identity remains confidential. To inform staff about the Whistleblowing tool of BaFin, the Federal Financial Supervisory Authority in Germany.
  • To make arrangements to ensure, if asked by the German Financial Intelligence Unit (Zentralstelle für Finanztransaktionsuntersuchungen) or by other competent authorities, to provide information as to whether the obliged entity maintained a business relationship with certain persons during a period of five years prior to the enquiry, and what the nature of that relationship was. To ensure that the information is transmitted safely and confidentially to the institution making the inquiry.
  • Outsourcing on the basis of contractual agreement, to engage third parties to implement internal safeguards if the obliged entity notifies the supervisory authority of this in advance. The supervisory authority may prohibit the transfer if
    1. the third party does not provide an assurance that the safeguards are implemented properly,
  • 2. the management capabilities of the obliged entity are impaired
  • 3. supervision by the supervisory authority is impaired.
  • To adhere to orders that the supervisory authority may consider as appropriate and necessary.
  • To apply the provisions of section 6, para. 1 to 6 of GwG in a manner appropriate to the level of risk, to the obliged entity on account of the kind of transactions it engages in or of the size of the business, in consideration of the risks with regard to money laundering and terrorist financing.
  • The money laundering reporting officer is responsible for compliance with the provisions under anti-money laundering regulations. The AML Compliance Officer is directly subordinate to the top management level.


  • Academic degree in a relevant area, usually either a diploma, Masters or State Examination degree in Economics or Law. A further certificate, e.g. certified Anti-Money Laundering Specialist, is a plus
  • At least 5 years of relevant professional experience, preferably including several years in the financial services industry
  • High competence in methods and typologies of money laundering and terrorist financing
  • Very good conceptual skills paired with high implementation orientation
  • Strong communication skills, both written and spoken, in German and English
  • The AML Compliance Officer must carry out her/his function in Germany. S/he must be the point of contact regarding compliance with the relevant provisions for the law enforcement agencies, for the authorities responsible for the detection, prevention and elimination of threats, for the German Financial Intelligence Unit and for the supervisory authority. S/he is to be granted sufficient powers and the means necessary  to carry out her/his function properly. In particular, s/he is to have or be given unrestricted access to all information, data, records and systems which could be of importance in the performance of their functions. The AML Compliance Officer is to report directly to the top management level. If the AML Compliance Officer intends to submit a report under section 43 para. 1 or is responding to a request for information from the German Financial Intelligence Unit under section 30 para. 3, s/he is not subject to the right of the top management level to issue instructions


  • Flexible working times
  • 40% discount on our online shop
  • Fresh fruits + drinks everywhere
  • Language courses (German & English)
  • Free sports courses & reduced price for gym membership
  • Mobility subsidy
  • Modern office in the city center of Hamburg
  • International working environment and English as company language
  • Agile work environment (MOVE) and cross-functional teams
  • Dog-friendly office

We take responsibility for creating an inclusive and exceptional environment where all genders, nationalities, and ethnicities feel welcomed and accepted exactly as they are. We believe that a diverse workforce essentially contributes to the ABOUT YOU culture. In order to maintain talent and diversity, we emphasize the care for physical health, mental health, and overall well-being. Our values and work ethics essentially contribute to our brand mission: empower acceptance and shape an inclusive, fair, and circular fashion culture.

Because of our strong growth, new challenges and possibilities arise all along to further develop oneself and the company. Our team consists of people from different areas of expertise – fashion, marketing, business and tech – we are driven and united by our passion. We motivate and support each other, we share our know-how and we are open towards different opinions and new ideas.

We are looking forward to receiving your application – preferably via our online application portal! Thus, we can ensure a faster process and for you it is very easy to upload your application documents.

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