Chief Compliance Officer - NBFC

Role and Profile: Chief Compliance Officer Exp: 15-25 Years Academic: Any Graduate+ CS, Law Graduate Preferred Location: Gurugram HR Role Objective: The CCO will be responsible for Establishing and Overseeing the End-to-End NBFC Regulatory Compliance Framework, Reactivation or Transformation of Dormant/Small NBFC, Establishment of Digital-Lending Operations, Transition From a founder-led or Lightly controlled Organisation to a Governed Regulated lender and NBFC-Middle Layer Environment governance framework. Led RBI Inspection, Regulatory Correspondence, Acquisition or change in control of an NBFC. Key Job Role and Responsibilities: - 1. End-to-end NBFC regulatory compliance not merely Companies Act, secretarial or legal work. - 2. RBI inspection or supervisory engagement, regulatory correspondence, notices, remediation plans and sustainable closure of observations. - 3. Establishment or material strengthening of an NBFC compliance framework, including policies, applicability registers, regulatory calendars, compliance-risk assessments, monitoring and Board reporting. - 4. Launch or scaling of digital lending products, preferably unsecured personal loans. - 5. DLA/LSP governance, outsourcing, KFS/APR, cooling-off, customer consent and data usage, direct fund flows, disclosures, grievance handling, collections and recovery conduct. - 6. KYC, CKYCR, AML/FIU, suspicious-transaction escalation, sanctions screening, CIC reporting and customer-dispute processes. - 7. Review of LOS/LMS and other lending-technology vendors, including configurations, maker-checker controls, audit trails, exception reporting, data access and regulatory evidence. - 8. Direct interaction with the Board, senior management, RBI, auditors and external advisers. - 9. Ability to work without a large existing team and progressively build a lean compliance function. Domain and Functional Expertise: A. Regulatory Compliance (RBI & Other Authorities): - 1. Develop, implement, and maintain compliance programs in line with RBI regulations for PA, cross-border PA, and PPI license holders. - 2. Act as the primary point of contact with RBI and FIU-IND for compliance, AML/CFT reporting, and regulatory inspections. - 3. Monitor and interpret regulatory developments; advise management and business units on compliance obligations. - 4. Ensure timely submission of regulatory returns, reports, and notifications to RBI and other authorities. - 5. Oversee compliance with Payment and Settlement Systems Act, Prevention of Money Laundering Act (PMLA), FEMA, and other relevant statutes. B. AML/CFT Framework: - 1. Establish and oversee AML/CFT policies, procedures, and systems, including risk-based KYC, CDD, EDD, and transaction monitoring. - 2. Ensure timely reporting of STRs (Suspicious Transaction Reports) and CTRs (Cash Transaction Reports) to FIU-IND. - 3. Conduct AML/CFT risk assessments and ensure controls are effective across business lines. - 4. Maintain and update sanctions screening processes (OFAC, UN, EU, domestic lists) for all customers and transactions. C. Governance & Oversight: - 1. Design and implement the compliance governance structure, including board-level reporting and risk committee presentations. - 2. Ensure compliance training programs for employees and agents are designed, rolled out, and tracked. - 3. Regularly review policies on data protection, consumer protection, outsourcing, grievance redressal, and fraud risk management as per RBI mandates. - 4. Lead compliance audits, reviews, and gap assessments, ensuring remediation of findings. - 5. Oversee vendor/partner due diligence from a compliance perspective, especially for cross-border arrangements. D. Strategic Business Partnership: - 1. Partner with business, operations, technology, and product teams to embed compliance and AML/CFT controls in processes. - 2. Support cross-border product launches and PPI innovations with compliance guidance. - 3. Anticipate regulatory expectations and proactively build systems that are regulator-ready. Qualifications & Experience: - 1. Minimum 10-20 years of Experience in Regulatory Compliance, Risk, or Legal roles within Digital Lending, Fintech, Banks or Payments industry. - 2. Strong knowledge of RBI regulations applicable to Payment Aggregators, PPIs, and Cross-Border Payment arrangements. - 3. Must have prior experience as an MLRO or senior AML officer, with deep familiarity with PMLA, FIU-IND guidelines, and AML/CFT frameworks. - 4. Proven ability to engage with RBI, FIU, and other regulators effectively. - 5. Law, Finance, or Compliance degree (LLB, CA, CS, MBA, or equivalent). CAMS/ICA certification preferred. Core Competence and Expertise in: - 1. Acquisition or change in control of an NBFC. - 2. Regulatory and legacy-compliance diligence. - 3. Reactivation or transformation of a dormant/small NBFC. - 4. Establishment of a digital-lending operation from the beginning. - 5. RBI inspections during a period of rapid growth. - 6. Transition from a founder-led or lightly controlled organisation to a properly governed regulated lender. - 7. An NBFC-Middle Layer environment or similarly mature governance framework. Please share the brief, Specific answers to the following: - a. Which RBI-regulated NBFCs have they worked in, and what were the exact entity category, layer, and their reporting line? - b. Which NBFC regulatory returns, compliance assessments and Board reports did they personally prepare or review? - c. What direct experience do they have with DLA/LSP, LOS/LMS, outsourcing and technology-vendor controls? - d. Have they handled an NBFC acquisition, change in control, licence-related process, legacy diligence, or greenfield setup?