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At PayPal (NASDAQ: PYPL), we believe that every person has the right to participate fully in the
global economy. Our mission is to democratize financial services to ensure that everyone,
regardless of background or economic standing, has access to affordable, convenient, and secure
products and services to take control of their financial lives.

Job Description Summary: The UK Head of Financial Crime/MLRO will be based in the UK and
will be accountable for ensuring all activity, conducted within PPUK, or globally on behalf of PPUK,
related to anti-money laundering and the prevention of terrorist funding is compliant with UK
expectations or ensure that any non-compliance is addressed or escalated to the Audit, Risk,
Compliance & Conduct Committee (ARCC) and/or PPUK Board where required. The PPUK Board
and Senior Management will ensure that the UK Head of Financial Crime/MLRO has the necessary
authority and status, is fully independent, with access to resources and information sufficient to
enable them to carry out their responsibilities. The UK Head of Financial Crime/MLRO will assume
the PPUK Money Laundering Reporting Function (SMF 17) and Nominated Officer responsibilities.
As a member of PPUK’s second of defence Risk and Compliance teams will report directly into the
second line of defence Chief Risk & Compliance Officer (CRCO) with the ability to escalate any
Financial Crime (AML, Sanctions and Anti-Bribery and Corruption) to the PPUK ARCC and PPUK
Board.

Job Description:
Accountable for effective oversight, control, and management of PPUK policies, procedures and
practices relating to UK AML and CTF issues, to include providing guidance, assistance, and
challenge on PPUK’s policies, procedures and practices including those executed on behalf of
PPUK by global teams and third parties that support PPUK execute its regulatory obligations.

Develop, implement, and manage UK AML and Counter Terrorist financing policy and procedures,
monitoring, and oversight program (to include PayPal’s Global policies and procedures where they
apply to the PPUK) in line with evolving statutory and regulatory obligations.

Work closely with colleagues based across the globe and relevant third parties to ensure that
PayPal’s Financial Crime related controls are designed and operating as per UK regulatory
requirements.

Support and coordinate management focus on the money laundering and CTF risk in individual
business areas in PPUK.

Assist management in developing and maintaining an effective AML and CTF compliance culture for
PPUK.

Ensure PPUK’s Financial Crime related risk management policies, Financial Crime risk assessment
profile, and application are adequately documented by the 1st line of defense. Ensure Annual
Business Risk Assessments for Financial Crime, Sanctions and Anti Bribery and Corruption are
conducted effectively.

Prepare the annual MLRO report in collaboration with the global PayPal business, using findings and
lessons learned from 1st,2nd 3-line assurance reviews, internal business changes and external
changes to the business environment to develop a UK picture of Financial Crime risks, issues and
controls across PayPal that impact PPUK.

In consultation with management and 1st line colleagues from across PayPal create and maintain
the money laundering risk-based approach and the risk assessment of PPUKs customers, products,
and services.

Establish and maintain appropriate Financial Crime risk-based monitoring processes proportionate
to PPUKs operations, scale, nature, and complexity.

Document PPUKs Financial Crime risk-based strategies and the basis for risk assessment and
monitoring.

Ensure immediate investigation of all internal SARs received by PayPal’s Global Financial Crime
and Consumer Protection (GFCCP) team.

Ensure the submission of a SAR by PayPal’s Global Financial Crime and Consumer Protection
(GFCCP) team to the relevant UK law enforcement agency (National Crime Agency) regarding all
suspicions that have substance as required pursuant to PPUK.

Monitor and encourage staff compliance with the PPUK AML & CTF policies and monitor operations
and development of the policy. Ensuring that any issues of concern are escalated to ARCC.

Provide management information and regular updated to ARCC and the PPUK Board as necessary,
including an annual report each year to PPUKs Board and senior management on PPUKs
compliance with its obligations.

Function as a primary point of contact for UK regulators, and in any other third-party enquiries on
PPUK’s AML and CTF approach.

Ensure that all relevant staff are adequately trained in money AML and CTF prevention, that the
standards and scope of the training are appropriate and that appropriate training records are kept.

Remain aware of any relevant sanctions, prohibitions, and notices. Also ensure that GFCCP
management and relevant staff ensure the names of any individuals and institutions on the UK
sanctions list are screened in a timely manner.

Provide sign-off on behalf of PPUK where required, to include the new product development
approval and launch process for UK products; for marketing materials relating to UK products and
for other policies; and for other relevant policies, procedures and practices which relate to, or impact
on, PPUK.

Accountable as the UK Head of Financial Crime/MLRO & Financial Crime advisor to the PPUK
Board and Senior Management.

Assist and guide the CEO and CRCO on SMCR Financial Crime related responsibilities.

Represent the interests of the PPUK, from an AML & CTF perspective, at meetings of PPUK and
global Financial Crime related committees.

Participate as a member of the UK Risk & Compliance Committee with direct access to the UK
ARCC and PPUK Board for escalation.

Escalate unresolved or ongoing unmitigated compliance gaps and issues to the UK Executive
Committee, UK ARCC and UK Board.

Ensure emerging regulatory obligations Highlight the need to stay updated with evolving statutory
and regulatory obligations, including any changes to AML and CTF legislation or guidelines.
Strengthen regulatory relationships on Financial Crime related matters: Establish a proactive
approach to engage with regulatory authorities on Financial Crime related matters, not just as a point
of contact but also by participating in relevant industry forums or working groups.

Set the appropriate ‘Tone from the Top’ by reinforcing, inputting to and tracking Financial Crime
training and awareness.

Take personal accountability for ensuring s/he remains up to date and can evidence the required
skills, knowledge, and abilities to continue to fulfil the requirements of the MLRO role.

To the extent not covered by the above, manage all UK Head of Financial Crime/MLRO associated
duties effectively, including reporting obligations and the implementation of systems and controls for
Anti Money Laundering, Counter Terrorist Financing, Tax Evasion facilitation prevention and other
anti-financial crime activities.

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