Sanja Ugrčić Pavlović, CFE
Belgrade, Serbia | Washington, D.C.
Summary
Risk and compliance executive with 11+ years of experience across crypto, fintech, and high-risk payments. Expert in EU crypto regulation and enterprise risk management, with a strong track record in AML/CTF, licensing, and building scalable frameworks. Recognized for embedding risk culture in regulated institutions and advising leadership on balancing growth and compliance. Certified Fraud Examiner (CFE) with leadership experience as COO, CRO, MLRO, and Head of Risk in fintech and crypto companies across Europe and Asia. International speaker on crypto regulation, financial services risk, and operational resilience.
Overview
12
12
years of professional experience
2
2
Certification
Work History
Chief Operating Officer (COO)
CEZA-Licensed Fintech
04.2025 - Current
- Lead operations, compliance, and settlement in a licensed crypto/EMI/PSP environment.
- Designed and embedded risk appetite and tolerance aligned with board strategy.
- Directed PSP integrations, licensing readiness, and SOP development.
Chief Risk Officer (CRO)
PSP Aggregator
04.2025 - Current
- Oversight of enterprise risk across FX and iGaming merchants.
- Designed and rolled out a risk management framework aligned with ISO 31000, including risk registers, KRIs, and dashboards.
- Implemented chargeback controls, fraud escalation mechanisms, and board-level reporting.
- Delivered evidence-based risk insights to executive team and regulators, ensuring growth within compliant boundaries.
Head of AML/CTF & Regulatory Compliance (MLRO)
iGaming Operator
04.2024 - 04.2025
- Built AML/CTF compliance framework in alignment with EU directives and FATF guidance.
- Managed audits, suspicious transaction reporting (STRs), and regulatory engagement.
- Partnered with product and legal teams to embed compliance into operations.
Director
Web3 & Blockchain Supercluster “Excellent 3”
02.2024 - 07.2024
- Appointed as Serbia’s first blockchain consortium Director fostering innovation and regulator dialogue.
- Led a regulatory gap analysis between MiCA and Serbia’s Digital Assets Law, providing strategic recommendations for alignment once MiCA becomes applicable.
- Advocated on EU crypto regulatory trends and risk management practices, bridging public–private cooperation.
Head of Risk & Compliance (MLRO)
ECD.rs – Licensed Crypto Exchange
04.2021 - 04.2024
- Directed risk and compliance at Serbia’s first licensed crypto exchange.
- Successfully implemented ISO 31000 risk management framework, approved by the National Bank of Serbia and the Republic of Serbia Securities Commission as part of licensing.
- Strengthened monitoring, reporting, and operational resilience in line with EU crypto regulatory standards.
- Developed and embedded ERM policies, KRIs, and business continuity planning.
Education
MA Candidate - Cultural Studies
University of Belgrade, Faculty of Political Sciences
10-2025
MSc - Economics
University of Belgrade, Faculty of Economics
01.2016
BSc - Economics
University of Belgrade, Faculty of Economics
01.2013
Skills
- EU Crypto Regulation – licensing, governance, disclosures, AML/CTF alignment
- Enterprise Risk Management (ERM) – framework design, KRIs, dashboards, risk appetite statements
- Risk Identification & Assessment – operational, ICT/operational resilience, liquidity, outsourcing, compliance, crypto-specific risks
- Risk Analysis & Continuity – scenario-based risk assessment, business resilience planning, and regulatory stress testing
- Leadership & Culture – risk enablement, executive partnership, regulatory engagement
- AML/CTF & Fraud Prevention – frameworks, investigations, chargeback and escalation management
Affiliations
- Vice President — ACFE Serbia Chapter (2023–Present)
- Board Member — ACFE Serbia Chapter (2022–2023)
Certification
- Certified Fraud Examiner (CFE), ACFE (2019)
- AML/CTF Licence, Ministry of Finance Serbia (Valid to 2026)
Timeline
Chief Operating Officer (COO)
CEZA-Licensed Fintech
04.2025 - Current
Chief Risk Officer (CRO)
PSP Aggregator
04.2025 - Current
Head of AML/CTF & Regulatory Compliance (MLRO)
iGaming Operator
04.2024 - 04.2025
Director
Web3 & Blockchain Supercluster “Excellent 3”
02.2024 - 07.2024
Head of Risk & Compliance (MLRO)
ECD.rs – Licensed Crypto Exchange
04.2021 - 04.2024
MSc - Economics
University of Belgrade, Faculty of Economics
BSc - Economics
University of Belgrade, Faculty of Economics
MA Candidate - Cultural Studies
University of Belgrade, Faculty of Political Sciences
Selected Speaking Engagements
- European Women Payments Network (EWPN) Annual Conference — Vienna, 2023: Panelist on “The (R)evolution in EU Financial Services Regulation,” covering MiCA, PSD2/PSD3, instant payments, the Digital Euro, and stablecoins.
- Digital Forensics Conference — Belgrade, 2023: Speaker on blockchain forensics, AML/CTF, and fraud prevention.
- Erste Security Conference — Belgrade, Oct 2024: Presenter on “Crypto Environment.”
- ACFE Serbia Conference: New Digital Trends in Business Protection — Belgrade, Nov 2024: Panel moderator on digital asset risk strategies.
- Digitalik Zrenjanin 2024 — Zrenjanin, Apr 2024: Panelist on the “Present and Future of Web3.”
- Risk Ready Conference — Zagreb, May 2023: Panelist on digital onboarding and fintech risk.
- Finticipate — SEE FinTech Forum — Belgrade, May 2023: Panelist on crypto fraud risks and sanctions.
- Forum of Advanced Technologies (TechFusion) — Niš, 2023: Panelist on blockchain adoption and Web3.
- Association of Serbian Banks Annual Compliance Conference — Belgrade, 2023: Speaker on crypto regulation and AML/CTF.
- #FraudAwarenessWeek (ACFE Serbia & Deloitte) — Belgrade, 2023: Speaker on crypto fraud and financial crime.
- Web3.fm Podcast — 2023: Guest on fraud prevention and crypto compliance.
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