General Counsel

First Circle is the leading and fastest growing, technology-led financial service business for SMEs in the Philippines. We've already transformed access to credit for thousands of businesses, and now we're building a full service digital-first small business bank offering multi-currency bank accounts, payments, FX, corporate credit cards, and payroll. As we enter this next phase of growth, we're hiring exceptional talent with a track record of excellence to join us in shaping the next chapter.

We’re looking for a General Counsel who is commercially and operationally minded and who can hold high standards across multiple workstreams at a fast pace.

The General Counsel leads legal, compliance, and risk functions across FCGFC and the broader CCG group, and also serves as Corporate Secretary. The role is broad by design, spanning seven core areas of ownership: general legal advisory, compliance, anti-money laundering, data protection, special projects, corporate housekeeping, and building out the legal team.

------------------------

Team construct

The General counsel is supported by a team of five: Legal Counsel, a paralegal, Head of Compliance, a Compliance Assistance and a general administrative assistant.

------------------------

Key Responsibilities:

1. General Legal Advice

Performance Objective: Legal is never the reason a transaction or project slips. Positions taken are commercial but defensible. Escalation is timely: material issues are escalated to the CEO/CIO.

• Provide legal advice and support for all operational and strategic matters of First Circle
• Advise on business expansion into new markets and new products, funding and other company-wide impact decisions
• Structure and negotiate transactions supporting business growth (financing, partnerships, M&A, new market entry)
• Serve as a key advisor on corporate governance matters, including board processes and shareholder matters

2. Compliance
Performance Objectives: No regulatory lapse across the group

• Oversee compliance for First Circle and all corporate group matters
• Ensure compliance coverage extends to expansion projects in other countries and other industries
• Maintain and keep current the group's regulatory compliance framework (BSP, SEC, and other applicable regulators)
• Manage relationships with regulators and coordinate with external counsel as needed

3. AML (Anti-Money Laundering)
Performance Objective: 100% of covered and suspicious transaction reports filed within the statutory deadline. Internal audit of AML programme produces no material / high risk findings.

• Supervise the AML function and act as or oversee the Anti-Money Laundering Officer (AMLO)
• Own and maintain the AML policy framework across FCGFC and group entities
• Oversee AML monitoring, reporting, and regulatory coordination with the AMLC

4. Data Protection
Performance Objective: No data protection lapses due to lack of or poorly implemented controls.

• Act as or oversee the Data Protection Officer (DPO) function
• Handle data privacy matters, including registration, compliance, and incident response
• Ensure compliance with the Data Privacy Act and NPC requirements across the group

5. Special Projects
Performance Objective: Deliver cross functional projects with minimal guidance

• Serve as the catch-all owner for ad hoc or special projects assigned to Legal (e.g., environmental and social policy work is one example, not the limit of scope)

6. Corporate Housekeeping
Performance Objective: Zero late or deficient statutory filings. Full corporate record set maintained. Any corporate record producible same day as requested.

• Act as Corporate Secretary for FCGFC
• Responsible for SEC certificates and filings (e.g., General Information Sheet, secretary's certificates, and other SEC submissions)
• Prepare, maintain, and safe-keep board and stockholders' meeting minutes and corporate records
• Ensure ongoing SEC compliance, including statutory deadlines and reportorial requirements
• Oversee corporate housekeeping for non-Philippine group entities (e.g., Singapore entities), working with local corporate secretaries/registered agents to ensure compliance.

7. Building the Legal Team
Performance Objective: Legal capability exists beyond one person.

• Build, recruit for, and lead the general legal team, including direct supervision of the Legal Counsel
• Provide supervision and coordination for legal and compliance functions across the CCG group (including subsidiaries and affiliated entities)
• Set legal and compliance priorities, workflows, and standards across the group

------------------------

A successful candidate is:

• Able to balance commercial mindedness with legal best practice
• Able to drive progress across multiple workstreams in a fast paced environment
• Comfortable voicing their opinions to strong-minded stakeholders
• Able to balance urgency with thoroughness
• Comfortable working in an expat-led organisation

Requirements

• 8+ years of relevant legal experience, with meaningful experience in a startup or fintech environment
• Strong background in compliance matters, including AML and data privacy regulatory frameworks
• Experience serving as, or working closely with, an AMLO and/or DPO
• Demonstrated experience managing or leading a legal team
• Experience advising on strategic, company-wide matters (expansion, new products, corporate transactions)
• Experience acting as Corporate Secretary, including SEC filings/certificates and minutes preparation
• Admitted to the Philippine bar in good standing

Benefits

• Hybrid work set-up: 2 days per week in our BGC office; remote the rest of the time.
• Additional perks & benefits: HMO coverage from week one, free catered lunches, monthly fitness allowance, transportation & accommodation allowance, and more.
• Join a team with a deeply collaborative culture! Learn more here: