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Set the quality standard for enhanced due diligence.
By ensuring bol becomes and remains a compliant financial service provider. You perform Enhanced Due Diligence on high-risk cases where standard processes are insufficient, including complex transaction monitoring investigations and behavioral risk assessments. Think partners in higher-risk countries, PEP cases, and more opaque structures and transactions. Here, your decisions will set precedents. Together with the team, you set the standard for proportionality and audit-proof documentation and translate individual cases, including transaction-based insights, into structural improvements.
You work in a dynamic, licensed environment where processes are not yet crystallized. Every case requires careful judgment. How thorough does EDD need to be? How do we ensure mitigations are proportional and compliant? When do you escalate to Compliance or the Client Acceptance Committee, and which decisions are within your purview? High-impact hits (sanctions, PEP, adverse media, complex transaction monitoring alerts and behavioral anomalies) demand meticulous, audit-proof decision-making that sets precedents for future cases. You navigate time pressure, regulatory requirements (DNB/AFM/FSMA/FIU), and practical feasibility, while coaching less experienced colleagues and safeguarding quality standards. You assess not only static customer risk, but also dynamic transaction behavior and its implications for ongoing risk exposure.
You’ll work within the CDD team that performs Client Due Diligence for bol financial services (bfs). The team reports to the Manager of CDD Operations, who in turn reports to the Head of CDD. You have no direct reports, but as a senior, you serve as an escalation point and coach for junior and mid-level analysts.
You handle non-standardized and/or high-risk cases or transactions, including complex transaction monitoring alerts and atypical behavioral patterns, determine the required depth of Due Diligence, determine measures that correspond to our risk appetite and comply with all legislation, and ensure audit-proof documentation, including clear evidence sets and decision rationales. You apply your in-depth knowledge of and experience with legislation, best practices, and market standards, tailored to the bol context.
In the event of screening hits (sanctions, PEP, adverse media, transaction monitoring), you lead the substantive assessment, determine the next steps, and document precedents. You also provide input for improving policies, procedures, tooling, and underlying models. You coach mid-level and junior colleagues through knowledge sessions, case discussions, and best practice sharing.
Your key responsibilities
You combine demonstrable CDD knowledge with experience in licensed environments, preferably in e-commerce. You apply legislation (Wwft, AMLR, sanctions legislation, supervisory requirements) proportionally and risk-based. You understand what DNB, AFM, and FSMA require in terms of case documentation and know how to set the appropriate EDD depth without overcompensating.
You’re analytically strong enough to draw connections between individual case findings, transactional behavior, and broader portfolio trends, and you translate those insights into improvements for work instructions, process flows, and risk models. When cases are escalated to you, you set precedents, safeguard assessment consistency, and coach colleagues, without formal QC review or people management responsibilities. You stay abreast of relevant legislation and developments, and understand risk factors in detail and how they apply at bol. To maximize your impact, it’s important that you have explicit transaction monitoring experience. And if your fortune cookie also contains Chinese language (Mandarin) skills, even better!
Not for you if
For you if
You’ll join the CDD team within bol’s FinTech organization, performing Client Due Diligence for bol financial services. You’ll report to the Manager of CDD Operations and work alongside CDD analysts, the Quality Reviewer, Compliance, and Fraud. The team is building a completely new CDD capability from 2026 onward, so you’ll be there from the very beginning. The atmosphere is professional and results-driven: we focus on compliance functions that enable innovation, and never block it. Growth opportunities within the expanding CDD team are realistic, particularly given the planned scale-up to 25–40 team members within two years.
We take pride in our B Corp certification and strive for continuous improvement every day. Our annual bonus is tied to sustainability goals.
Bij bol leveren onze collega’s een unieke bijdrage om het dagelijks leven makkelijker te maken. Vrijheid en verantwoordelijkheid zorgen ervoor dat we samen de volgende stap voor bol, het team, en onszelf kunnen vormgeven. Door te pionieren brengen we bol verder, met elkaar zijn wij verantwoordelijk voor deze gezamenlijke missie.
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