The Head of Fraud is responsible for establishing, implementing, and maintaining KIRA Financial Brokers LLC's integrated Fraud Management Framework across all licensed activities: CAT 1 (OTC & International Market brokerage), CAT 5 (Financial Consultations, Introduction, Promotion), and pending CAT 2 (Fund & Portfolio Management).
This role leads the Firm's zero-tolerance approach to fraud, ensuring robust prevention, detection, investigation, and reporting mechanisms. The Head of Fraud operates as a Second Line of Defense (2LOD) function, independent of business operations, with direct functional reporting to the CEO to ensure impartiality in fraud investigations. The role ensures full compliance with SCA anti-fraud requirements, AML/CFT regulations, and Conduct of Business rules.
Key Responsibilities
1. Framework & Policy Governance
· Own, maintain, and update the Fraud Management Policy, ensuring it remains current, Board-approved, and aligned with SCA regulations.
· Lead the annual policy review cycle and initiate ad-hoc reviews following regulatory changes, material fraud incidents, or new license approvals (e.g., CAT 2).
· Ensure the Fraud Management Framework is integrated with the Firm's Enterprise Risk Management (ERM) system and other governance policies (Code of Conduct, AML/CFT, Risk Management).
2. Fraud Prevention
· Establish and maintain a comprehensive preventive control framework across all business units.
· Oversee pre-employment screening for fraud-sensitive roles, including criminal record checks, credit checks (where permitted), and adverse media searches.
· Ensure robust client due diligence (CDD/EDD) processes to prevent identity fraud, account takeover, and synthetic identity fraud.
· Conduct third-party due diligence for vendors, introducers, and consultants (CAT 5 specific), including fraud risk assessments and annual re-validation.
· Design and deliver role-based fraud awareness training for all employees, Board members, and relevant third parties.
3. Fraud Detection
· Implement and maintain automated transaction monitoring systems for CAT 1, CAT 5, and financial payment fraud detection.
· Establish manual review and reconciliation procedures (daily, weekly, monthly, quarterly) to identify fraud indicators.
· Administer the Firm's confidential whistleblowing channel, ensuring accessibility, anonymity (if desired), and protection against retaliation.
· Utilize data analytics (including duplicate detection, ratio analysis) to proactively identify anomalies and fraud patterns.
· Coordinate with Internal Audit on surprise audits and forensic reviews.
4. Fraud Investigation
· Lead or coordinate all fraud investigations (internal and external) involving the Firm, its employees, clients, or third parties.
· Apply investigation principles of independence, objectivity, confidentiality, timeliness, and preservation of evidence.
· Implement immediate preventive actions ("Hold and Secure") upon fraud suspicion: transaction holds, account freezes, system access suspension, and evidence preservation.
· Manage chain-of-custody for all evidence (electronic, documentary, testimonial, physical).
· Conduct witness and subject interviews in accordance with legal and HR requirements.
· Prepare comprehensive investigation reports including findings, loss quantification, root cause analysis, control gaps, and recommendations.
5. Reporting & Regulatory Compliance
· Maintain the Fraud Incident Register with complete, accurate records of all confirmed fraud incidents.
· Prepare and present quarterly fraud summary reports and annual fraud reports to the Board of Directors.
· Coordinate with the Compliance Officer on regulatory reporting to the SCA, including Fraud Incident Reporting (FIR) Forms within required timelines.
· Ensure timely reporting of criminal fraud to UAE law enforcement (police, Public Prosecutor).
· File Suspicious Transaction Reports (STRs) with the UAE Financial Intelligence Unit (FIU) when fraud involves money laundering indicators.
· Coordinate fraud-related insurance claims (fidelity bond / crime insurance) with the Account / Finance Officer.
6. Recovery & Remediation
· Pursue loss recovery actions: restitution agreements, civil lawsuits, asset freeze (where legally permitted).
· Ensure control enhancements identified during investigations are implemented and tested.
· Integrate lessons learned from fraud incidents into training materials and Policy updates.
7. Case Closure & Continuous Improvement
· Formally close fraud cases when all required actions are complete (investigation, disciplinary action, regulatory reporting, insurance resolution, control enhancements).
· Facilitate lessons learned sessions with relevant stakeholders.
· Recommend Policy amendments based on emerging fraud typologies, detection gaps, or regulatory changes.
8. Culture & Awareness
· Promote a culture of integrity, ethical behavior, and zero tolerance for fraud throughout the organization.
· Champion the "tone from the top" by reinforcing Board and Senior Management commitment to fraud prevention.
· Ensure all employees understand their obligation to report suspected fraud without fear of retaliation.
Education
Bachelor's degree in Criminology, Forensic Accounting, Law, Finance, Business Administration, or related field. Master's degree or MBA preferred.
Experience
Minimum 8–10 years of progressive experience in fraud management, forensic accounting, or corporate investigations, with at least 3–5 years in a leadership role. Direct experience in an SCA-regulated entity (brokerage, investment firm, or bank) is strongly preferred.
Regulatory Knowledge
Deep understanding of SCA Decision No. (13/Chairman) of 2021, UAE fraud laws, AML/CFT regulations, and UAE Labor Law as it relates to disciplinary actions and termination for fraud.
Technical Skills
Proficiency in fraud detection systems, transaction monitoring, data analytics tools, forensic examination techniques, and chain-of-custody procedures.
Key Competencies
· Investigative Rigor
· Analytical Thinking
· Independence & Impartiality
· Legal & Regulatory Acumen
· Communication
· Integrity & Ethics
· Courage
Working Conditions & Special Requirements
· Confidentiality – Access to highly sensitive investigation files; must maintain strict confidentiality.
· After-Hours Work – May be required to respond to fraud alerts or incidents outside normal business hours.
· Travel – May be required to conduct site visits, attend court proceedings, or meet with regulators.
· Stress Management – Ability to manage high-pressure situations involving potential financial loss, regulatory scrutiny, or employee misconduct.
Work Location: In person
