Company Secretary | Compliance Officer | Principal Officer (PMLA)

Bhawana Capital is the Indian lending entity of Multitude Group, a listed European financial services group. We are an RBI-registered NBFC lending through a partner-led origination model, working with Loan Service Providers, and we are building the India business from an early base towards a substantially larger loan book.

This is a single-owner compliance role. You will not be joining a compliance department. You will be establishing one, and you will hold the statutory positions that go with it in your own name.

What You Will Own

Regulatory compliance — RBI

• All RBI compliance obligations applicable to a Base Layer NBFC, including the Master Directions on KYC, outsourcing of financial services, fair practices and digital lending
• Preparation and filing of periodic regulatory returns
• The compliance policy framework end to end — drafting, board approval, annual review and testing
• First point of contact for RBI correspondence, inspections and queries

AML and CFT — PMLA

• Appointment as Principal Officer under the PMLA and registration with FIU-IND
• The AML/CFT policy, the ML/TF risk assessment and customer risk categorisation
• STR, CTR and related reporting to FIU-IND
• Sanctions and PEP screening, and obligations under Section 51A of the UAPA
• CKYCR upload and search, V-CIP and periodic re-KYC

Partner and outsourcing oversight

• Compliance oversight of Loan Service Providers, covering customer-facing conduct, data handling, recovery practices, Key Fact Statement delivery and default loss guarantee arrangements
• Due diligence and periodic review of outsourced arrangements

Company secretarial and governance

• Board and committee process — agendas, papers, minutes and statutory registers
• MCA and ROC filings, and Companies Act compliance generally
• Support to the Board and the Designated Director on governance matters

Group

• Reporting to the Group MLRO on financial crime matters, and contributing to Group-level compliance reporting and assurance.

What We Are Looking For

• A qualified Company Secretary (ACS) with roughly four to eight years of post-qualification experience in an NBFC or another RBI-regulated entity
• Hands-on experience of RBI regulatory returns, board and committee process, and MCA and ROC filings for a regulated entity
• A working knowledge of the PMLA framework. You may have supported a Principal Officer rather than held the position yourself, and that is fine
• Comfort operating without a team around you. This is a build role rather than a maintenance role, and the person who enjoys it will be someone who has been waiting for the chance to own something
• Exposure to digital lending, LSP or co-lending arrangements, or the RBI Digital Lending Directions is an advantage, but it is not a requirement. We can teach the Directions; we cannot teach regulatory judgement
• An AML certification such as CAMS is preferred. If you do not hold one, we will fund it and support you in obtaining it within twelve months