
Agoda · Bangkok
About Agoda At Agoda, we bridge the world through travel. Our story began in 2005, when two lifelong friends and entrepreneurs, driven by their passion for tra...
About Agoda
At Agoda, we bridge the world through travel. Our story began in 2005, when two lifelong friends and entrepreneurs, driven by
their passion for travel, launched Agoda to make it easier for everyone to explore the world.
Today, we are part of Booking Holdings [NASDAQ: BKNG], with a diverse team of over 7,000 people from 90 countries, working
together in offices around the globe. Every day, we connect people to destinations and experiences, with our great deals across
our millions of hotels and holiday properties, flights, and experiences worldwide.
No two days are the same at Agoda. Data and technology are at the heart of our culture, fueling our curiosity and innovation. If
you’re ready to begin your best journey and help build travel for the world, join us.
In the age of technology, things are constantly changing. The travel market is much the same, being more dynamic and complex than
ever. Agoda’s Legal team is well suited to take on the challenges presented, adopting a proactive mindset to tackle challenges and
solve problems. We are quick on our feet, decisive, and collaborate with multiple departments. We hire out-of-the-box thinkers
that are well grounded with ethics and legal knowledge to ensure that Agoda achieves the right results, the right way.
As Senior Counsel, Privacy (Fintech area) – you will be part of a leading and innovative team responsible for the legal risk areas
of data privacy, cybersecurity and artificial intelligence. This is a role dedicated to supporting fintech products and payments.
You will act as dedicated point of contact to fintech stakeholders across the company on the legal aspects of privacy,
cybersecurity and artificial intelligence, and maintain close cross-functional collaboration with sister brands within the Booking
Holdings group. This is a unique opportunity to shape key fintech initiatives from the ground up, with high visibility across
Agoda and other Booking Holdings brands.
for eligible candidates to ensure a smooth transition to working and living in Bangkok. Please note that remote work or working
from locations outside of Bangkok is not available for this role.
fintech products, interests and payment initiatives across the globe.
to fintech and payment operations (e.g. EU GDPR, UK GDPR and Data (Use and Access Act), CCPA, PDPA, PIPA, APPI, GLBA, PSD2).
as with other functions and brands in the Booking Holdings group, to embed privacy-by-design and compliance
principles throughout product and data lifecycles. Lead and support privacy impact assessments, and data mapping exercises.
terms in contracts with payment service providers, tech service providers, and fintech partners.
financial regulatory authorities in relevant jurisdictions.
e-privacy compliance, and regulatory change implementation.
management, template development, and continuous improvement of privacy processes.
collaboratively in a fast-paced, matrixed environment.
#LI-DN2 #Bangkok #Kualalumpur #Amsterdam #London #Paris #NewDelhi #Jakarta #Singapore #Hongkong #berlin #Sydney #Melbourne #Milan
#Rome #Madrid #Barcelona #New York #Vancouver #California
PLEASE REVIEW OUR HIRING PROCESS GUIDELINES BEFORE YOUR INTERVIEW — CLICK HERE TO LEARN HOW INTERVIEWING AT AGODA WORKS.
Equal Opportunity Employer
At Agoda, we pride ourselves on being a company represented by people of all different backgrounds and orientations. We prioritize
attracting diverse talent and cultivating an inclusive environment that encourages collaboration and innovation. Employment at
Agoda is based solely on a person’s merit and qualifications. We are committed to providing equal employment opportunity
regardless of sex, age, race, color, national origin, religion, marital status, pregnancy, sexual orientation, gender identity,
disability, citizenship, veteran or military status, and other legally protected characteristics.
We will keep your application on file so that we can consider you for future vacancies and you can always ask to have your details
removed from the file. For more details please read our privacy policy.
Disclaimer
We do not accept any terms or conditions, nor do we recognize any agency’s representation of a candidate, from unsolicited
third-party or agency submissions. If we receive unsolicited or speculative CVs, we reserve the right to contact and hire the
candidate directly without any obligation to pay a recruitment fee.
About Agoda At Agoda, we bridge the world through travel. Our story began in 2005, when two lifelong friends and entrepreneurs, driven by their passion for travel, launched Agoda to make it easier for everyone to explore the world. Today, we are part of Booking Holdings [NASDAQ: BKNG], with a diverse team of over 7,000 people from 90 countries, working together in offices around the globe. Every day, we connect people to destinations and experiences, with our great deals across our millions of hotels and holiday properties, flights, and experiences worldwide. No two days are the same at Agoda. Data and technology are at the heart of our culture, fueling our curiosity and innovation. If you’re ready to begin your best journey and help build travel for the world, join us. Our Company Booking Holdings (NASDAQ: BKNG) is the world’s leading provider of online travel & related services, provided to consumers and local partners through five primary B2C brands: Booking.com, Agoda, Priceline, KAYAK, and OpenTable. Collectively, Booking Holdings operates in more than 220 countries and territories in Europe, North America, APAC, South America, the region, the Middle East and Africa in more than 40 languages. The mission of Booking Holdings is to make it easier for everyone to experience the world. The Opportunity Within Booking Holdings, a new, stand‑alone B2B entity will consolidate the B2B businesses of Booking.com, Priceline and Agoda into a single global division (“New B2B Business”). The New B2B Business will bring together our strategic partnerships, affiliate & API distribution, corporate and wholesale travel and other B2B commercial channels into one integrated platform serving airlines, travel management companies, OTAs, financial institutions, platforms and other strategic partners. You will work closely with colleagues at Booking Holdings Inc., Booking Holdings Financial Services, and sister brands, as well as internal partners across FinTech, Product, Fraud, Legal, Internal Audit, People, and Supply, to launch and support the New B2B Business. Agoda will support the New B2B Business across the relevant legal domains. This includes providing the necessary data privacy support in respect of the setup of the core components of the New B2B Business’s privacy program, as well as for all associated privacy advisory and contractual matters. Reporting to Agoda’s Chief Privacy Officer, you will as Principal Counsel, provide senior programmatic and advisory support to the New B2B Business as outlined in the role description below. This position is based in Bangkok. Agoda provides relocation support for successful candidates not currently located in Bangkok. Remote or alternative base locations are not available. In this Role, You’ll Get To: Play a central role in the original design, set up and support for the New B2B Business’s privacy program, as well as provide the necessary advisory support across a number of different matters set out below. Privacy Program: * Design, set up and implementation of the New B2B Business’s privacy program: In conjunction with Agoda’s Privacy Program team, help design, advise on and build the privacy program of the New B2B Business. This includes its records of processing activities, drafting and implementation of relevant privacy policies and outward facing notices, privacy by design processes including for privacy impact assessments, as well as providing the necessary programmatic support for incident response, international data transfers (including data sharing), and data subject rights. Privacy advisory support: * Contracting, negotiations and templates: you will build out the necessary data protection contractual templates, and handle relevant privacy contractual negotiations for the New B2B Business. * Privacy by design and by default: through early, positive interactions and impact assessments you will provide our product teams with clear, practical privacy advice building in key privacy by design concepts for various initiatives. In conjunction with Agoda’s Chief Privacy Officer, you will need to be able to take responsible risk positions outlining risk while working with other members of the Legal team and enabling the business to move forward * Marketing and cookies: you will be expected to understand, navigate and provide practical privacy counsel to our marketing teams across relevant marketing initiatives * Regulatory change management for existing, new, and amended data protection laws relevant to the New B2B Business: you will handle and manage the relevant privacy compliance aspects with global privacy laws, new and existing * Program, auditing and controls: Working closely with our Privacy Program team you will facilitate and manage key aspects of the privacy program, audits and enable reporting obligations * Contribute to brand initiatives within the Booking Holdings Inc. family: you may be expected to contribute and have meaningful impact across brands through cross-brand initiatives, forums, networks and offsites * General privacy support: As may be required, you will need to support relevant regulatory enquiries, authority demand requests and escalations relating to data subject rights What You’ll Need to Succeed * Experience & Expertise * 8+ years of progressive experience in data privacy preferably as a lawyer, and/or in risk management. * A relevant privacy certification e.g. CIPP/E, CIPP/US or CIPP/A. * Relevant experience with data privacy laws globally with a strong preference in the EU market. * Technical & Functional Skills * Hands on experience designing and operationalizing privacy programs. * Strong ability to use relevant privacy technology e.g. OneTrust in order to facilitate the core aspects of a data privacy program. * Leadership & Stakeholder Management * Demonstrated success in influencing and partnering with senior stakeholders across functions (Product, FinTech, Fraud, Legal, Internal Audit, Operations) in fast paced, high growth environments. * Strong project and program management skills, with the ability to prioritize, plan, and deliver multiple initiatives concurrently across jurisdictions and time zones * Excellent communication skills in English (written and verbal), with the ability to explain complex financial crime and compliance concepts in clear, business friendly terms. * Mindset & Values * Strategic, data driven, and solutions oriented, with the ability to “connect the dots”, see the big picture, and drive constructive change. * High level of integrity and sound judgement * Self-starter who operates with minimal supervision, is comfortable with ambiguity, and thrives in a dynamic, tech driven, international environment. PLEASE REVIEW OUR HIRING PROCESS GUIDELINES BEFORE YOUR INTERVIEW — CLICK HERE TO LEARN HOW INTERVIEWING AT AGODA WORKS. DISCOVER MORE ABOUT WORKING AT AGODA * Agoda Careers https://careersatagoda.com * Facebook https://www.facebook.com/agodacareers/ * LinkedIn https://www.linkedin.com/company/agoda * YouTube https://www.youtube.com/agodalife Equal Opportunity Employer At Agoda, we pride ourselves on being a company represented by people of all different backgrounds and orientations. We prioritize attracting diverse talent and cultivating an inclusive environment that encourages collaboration and innovation. Employment at Agoda is based solely on a person’s merit and qualifications. We are committed to providing equal employment opportunity regardless of sex, age, race, color, national origin, religion, marital status, pregnancy, sexual orientation, gender identity, disability, citizenship, veteran or military status, and other legally protected characteristics. We will keep your application on file so that we can consider you for future vacancies and you can always ask to have your details removed from the file. For more details please read our privacy policy. Disclaimer We do not accept any terms or conditions, nor do we recognize any agency’s representation of a candidate, from unsolicited third-party or agency submissions. If we receive unsolicited or speculative CVs, we reserve the right to contact and hire the candidate directly without any obligation to pay a recruitment fee.
About Agoda At Agoda, we bridge the world through travel. Our story began in 2005, when two lifelong friends and entrepreneurs, driven by their passion for travel, launched Agoda to make it easier for everyone to explore the world. Today, we are part of Booking Holdings [NASDAQ: BKNG], with a diverse team of over 7,000 people from 90 countries, working together in offices around the globe. Every day, we connect people to destinations and experiences, with our great deals across our millions of hotels and holiday properties, flights, and experiences worldwide. No two days are the same at Agoda. Data and technology are at the heart of our culture, fueling our curiosity and innovation. If you’re ready to begin your best journey and help build travel for the world, join us. Our Company Booking Holdings (NASDAQ: BKNG) is the world’s leading provider of online travel & related services, provided to consumers and local partners through five primary B2C brands: Booking.com, Agoda, Priceline, KAYAK, and OpenTable. Collectively, Booking Holdings operates in more than 220 countries and territories in Europe, North America, APAC, South America, the region, the Middle East and Africa in more than 40 languages. The mission of Booking Holdings is to make it easier for everyone to experience the world. The Opportunity As the building block that provides a solid baseline for Agoda’s culture of integrity, the Compliance & Ethics team is at the forefront of driving and maintaining the company’s compliance program and managing regulatory risks across a fast‑growing, tech‑driven global travel business. Within Booking Holdings, an enhanced and more connected global B2B organization is being built, bringing together strategic partnership capabilities across Booking.com, Priceline and Agoda ("New B2B Business"). Intended to better serve partners, move faster in the market, and unlock new opportunities for growth, the new organization will support strategic partnerships, affiliate and API distribution, corporate and wholesale travel, and other commercial channels, serving airlines, travel management companies, OTAs, financial institutions, platforms and other strategic partners. You will collaborate closely with colleagues across Booking Holdings Inc., Booking Holdings Financial Services, our sister brands, and key functions including FinTech, Product, Commercial, Legal, Internal Audit, People and Supply to help shape and support the next chapter of Booking Holdings' B2B business, leveraging the company's scale, technology, talent and global reach to create best-in-class partner experiences and innovative solutions. Reporting to the Agoda Senior Director, Compliance Officer, you will be the senior payments compliance lead for Agoda’s B2B (business to business) division, with a particular focus on our B2B payments products and related licensing obligations. You will design, enhance, and oversee our compliance risk management and control framework and provide pragmatic, risk-based advice to senior stakeholders. This position is based in Bangkok. Agoda provides relocation support for successful candidates not currently located in Bangkok. Remote or alternative base locations are not available. In this Role, You’ll Get To * Play a central role in helping design and implement the Compliance foundations of the new consolidated B2B business, including: Compliance & Ethics Programme – Key Responsibilities * Lead and support day‑to‑day Compliance & Ethics initiatives, ensuring key objectives, deliverables, and reporting are completed in a timely and high‑quality manner. * Act as a subject matter expert and trusted advisor on broader Compliance & Ethics topics (e.g., anti‑bribery and corruption, conflicts of interest, third‑party risk, code of conduct), providing well‑reasoned, business‑oriented guidance that supports Agoda’s culture of integrity. * Shape and enhance Agoda’s Compliance & Ethics framework, including policies, standards, training, monitoring and testing activities, ensuring it remains fit‑for‑purpose and aligned with Booking Holdings’ expectations and global benchmarks. * Design and oversee practical review processes for gifts and entertainment, conflicts of interest disclosures, third‑party due diligence, risk assessments, and related monitoring, and drive appropriate mitigation actions in close partnership with relevant stakeholders. * Collaborate with the Global Compliance & Ethics team on third‑party risk management initiatives and conflicts of interest processes, helping to ensure effective identification, escalation, and mitigation of key risks across new and existing activities. * Support or lead elements of compliance‑related reviews and investigations (where appropriate), and develop data‑driven monitoring approaches to identify trends, root causes, and opportunities for programme uplift. * Develop, implement, and continuously refine compliance policies, procedures, and standard operating procedures (SOPs) to keep pace with evolving business models and regulatory expectations. * Support the design, delivery, and refresh of compliance training programmes, including in‑person and virtual sessions, and maintain e‑learning materials in line with changing business needs and risk profiles. * Promote a strong ethical culture through awareness campaigns, employee engagement initiatives, and regular collaboration with key functions and leadership. * Partner closely with cross‑functional teams (e.g., Legal, Finance, Government Affairs, People, Commercial, Supply and other business stakeholders) to embed compliance requirements into products, processes, and day‑to‑day decision‑making. * Drive continuous improvement and efficiency initiatives, including the smart use of technology and digital tools to standardise, automate, and streamline compliance workflows. * Prepare or support management updates, reporting materials, and other compliance‑related communications for internal and external stakeholders and leadership. * Take on additional and ad hoc responsibilities as needed to strengthen the Compliance & Ethics function and further mature the overall programme. * Support the development, implementation and continuous enhancement of the financial crime risk management framework alongside our Financial Crime team. * Assist in areas of financial crime risk management such as testing and monitoring and annual risk assessment process. What You’ll Need to Succeed Experience & Expertise * 8+ years of progressive experience in compliance risk management regulatory compliance, preferably in global or regional organisations. * Significant cards and payments experience, including a practical understanding of consumer and B2B payments products, payment service provider models, card scheme rules, and payments licensing environments. * Proven track record in building, enhancing, or independently assessing compliance risk management frameworks for payments, including risk assessments, controls design, and governance. Technical & Functional Skills * Hands‑on experience designing, operating, or overseeing a corporate compliance framework, third‑party due diligence processes, investigations, escalation, and complex case handling. * Strong ability to translate legal and regulatory compliance into clear, pragmatic controls and processes that enable business growth while managing risk. Leadership & Stakeholder Management * Demonstrated success in influencing and partnering with senior stakeholders across functions (e.g., Product, FinTech, Commercial, Legal, Internal Audit, Operations) in fast‑paced, high‑growth environments. * Strong project and programme management skills, with the ability to prioritise, plan, and deliver multiple initiatives concurrently across jurisdictions and time zones. * Excellent communication skills in English (written and verbal), with the ability to explain complex compliance concepts in clear, business‑friendly terms. Mindset & Values * Strategic, data‑driven, and solutions‑oriented, with the ability to “connect the dots”, see the big picture, and drive constructive change. * High level of integrity and sound judgement, suitable for a senior Compliance & Ethics leadership role. * Self‑starter who operates with minimal supervision, is comfortable with ambiguity, and thrives in a dynamic, tech‑driven, international environment. PLEASE REVIEW OUR HIRING PROCESS GUIDELINES BEFORE YOUR INTERVIEW — CLICK HERE TO LEARN HOW INTERVIEWING AT AGODA WORKS. DISCOVER MORE ABOUT WORKING AT AGODA * Agoda Careers https://careersatagoda.com * Facebook https://www.facebook.com/agodacareers/ * LinkedIn https://www.linkedin.com/company/agoda * YouTube https://www.youtube.com/agodalife Equal Opportunity Employer At Agoda, we pride ourselves on being a company represented by people of all different backgrounds and orientations. We prioritize attracting diverse talent and cultivating an inclusive environment that encourages collaboration and innovation. Employment at Agoda is based solely on a person’s merit and qualifications. We are committed to providing equal employment opportunity regardless of sex, age, race, color, national origin, religion, marital status, pregnancy, sexual orientation, gender identity, disability, citizenship, veteran or military status, and other legally protected characteristics. We will keep your application on file so that we can consider you for future vacancies and you can always ask to have your details removed from the file. For more details please read our privacy policy. Disclaimer We do not accept any terms or conditions, nor do we recognize any agency’s representation of a candidate, from unsolicited third-party or agency submissions. If we receive unsolicited or speculative CVs, we reserve the right to contact and hire the candidate directly without any obligation to pay a recruitment fee.
About Agoda At Agoda, we bridge the world through travel. Our story began in 2005, when two lifelong friends and entrepreneurs, driven by their passion for travel, launched Agoda to make it easier for everyone to explore the world. Today, we are part of Booking Holdings [NASDAQ: BKNG], with a diverse team of over 7,000 people from 90 countries, working together in offices around the globe. Every day, we connect people to destinations and experiences, with our great deals across our millions of hotels and holiday properties, flights, and experiences worldwide. No two days are the same at Agoda. Data and technology are at the heart of our culture, fueling our curiosity and innovation. If you’re ready to begin your best journey and help build travel for the world, join us. Get to Know our Team: In the age of technology, things are constantly changing. The travel market is much the same, being more dynamic and complex than ever. Agoda’s Legal team is well suited to take on the challenges presented, adopting a proactive mindset to tackle challenges and solve problems. We are quick on our feet, decisive, and collaborate with multiple departments. We hire out-of-the-box thinkers that are well grounded with ethics and legal knowledge to ensure that Agoda achieves the right results, the right way. The Opportunity: This is an exciting opportunity to lead, develop and grow a role within the Commercial and Corporate Team. Seeking a senior, seasoned, able, confident, curious and self-motivated lawyer (to be based in Bangkok) to join the Agoda Commercial and Corporate Legal team who will work closely with other stakeholders in the Booking Holdings group and particularly with colleagues across the Group brands. This is an important role, reporting to the VP of Commercial and Corporate, leading and owning the relations with the Supply team that manages 100% of Agoda’s property relationships. There is a high focus on supply contracts, B2B relationships, all matters relating to hotel/property relationships, general commercial matters and Supply Team operational improvements. You will have an opportunity to be the sole POC for what is one of Agoda’s most dynamic and important teams – right at the heartbeat of the Agoda model. *This role is based in Bangkok, with relocation and work visa provided for those who aren't yet based in-market **No full-remote options In this Role, you'll get to: * Be the key decision maker for certain legal decisions in conjunction with business stakeholders and escalates other key decisions. You will ensure collaborative engagement with teams across the Agoda Legal Team and manage escalations to senior management (including GC and CEO). * Draft and negotiate international, commercial agreements with a focus on strategic partnerships, B2B, supply distribution, new initiatives, marketing, and public relations. * Own and lead the legal support with a critical business partner that covers 100% of all supply relationships for Agoda. With a small team you will help develop junior team members coaching and mentoring. * Actively engage with Agoda senior management at a C-suite level. * Provide well-reasoned, practical legal advice on a wide-range of legal and business matters and processes. You will be the “go to person” for the Supply team and will dovetail your priorities with their priorities and strategy. * Be fully autonomous for management of the legal Supply team together with the creation and delivery of departmental and team objectives. * For Supply stakeholders – lead the provision of advice, strategic direction and commercial solutions relating to litigation and disputes. Managing these with smart, innovative and P&L focused solutions. Draft key agreements with hotel partners, manage disputes and drive continual improvement and innovation. * As a true business partner, to maintain regular communication with key business teams, including senior level management, global legal team, finance and tax, and external counsel. * Drive and implement contract standards and controls, including that which happens at the holding company and/or sister-brand level. * Be the lead contact to drive new policies, procedures, training, and templates with the goal of fostering efficiency and compliance – with a lens on efficiency and innovation. * Influence senior stakeholders on innovative implementation of key legislation across broad legal areas specific to Supply. * Support the VP of Commercial and Corporate in ideation and implementation of pan team strategies, initiatives and innovation. You will work across the Agoda legal team driving collaboration, efficiencies and a deep level of cross team engagement. What you'll Need to Succeed: * 12+ years post qualified experience with a high level of impact. * Demonstrable ability to work autonomously with proven management and leadership experience of small-medium sized teams. High level of commercial awareness and business acumen. * Autonomous ability to manage and lead a multitude of complex and strategic legal matters and demonstrates a broad vision for the function. Ability to create, drive and own a strategy for the Supply legal team ensuring that vision and strategy is aligned with the annual business goals. * 1st class communication (verbal and written) and organization skills with high level of English proficiency. Exceptional legal drafting skills. * Experience in negotiating and influencing high complexity and risk matters externally (including government authorities). * Have the ability to provide commercial, innovative legal solutions to a fast paced and challenging business partner. A passion to drive efficiencies and process improvement – including the use of Gen AI. * Qualified lawyer/attorney with current entitlement to practice. Strong academic credentials, top-tier law firm experience plus prior in-house and significant contracting and commercial experience. * History of providing simple, concise & pragmatic advice for legal matters with high complexity and risk or strategic importance, always ensuring communications cut through complexities, are simple, avoid jargon and appropriate for the target audience. Making the complex simple with a wide range of stakeholders. * Deep experience in dealing with general commercial contracting matters, B2B relationships, procurement and disputes – ideally within the travel or B2B space. This role will be the sole contact for all supply related matters (including disputes) for the Agoda One Supply division. * Proactively anticipating issues that are yet to come for the business supported areas with holistic awareness across the organization. Create innovative solutions that take account of risk appetite and business goals. * Interact with colleagues, both legal and commercial, from the Supply/Key Accounts teams as well as Product Team to drive collaboration, consistency and alignment of operational practices. * Ability to work independently from intake through execution and work closely with business partners on solutions and innovative process improvements. * Aligned with the Agoda values and in particular Legal Teams “Values in Action”. * A demonstrated can-do, roll up your sleeves, collaborative approach, coupled with a strong work ethic and sound judgment. * Experience with travel industry/technology. * Ability to forge trusted relationships with colleagues around the world. #LI-DN2 #Bangkok #Kualalumpur #Amsterdam #London #Paris #NewDelhi #Jakarta #Singapore #Hongkong #berlin #Sydney #Melbourne #Milan #Rome #Madrid #Barcelona #New York #Vancouver #California PLEASE REVIEW OUR HIRING PROCESS GUIDELINES BEFORE YOUR INTERVIEW — CLICK HERE TO LEARN HOW INTERVIEWING AT AGODA WORKS. DISCOVER MORE ABOUT WORKING AT AGODA * Agoda Careers https://careersatagoda.com * Facebook https://www.facebook.com/agodacareers/ * LinkedIn https://www.linkedin.com/company/agoda * YouTube https://www.youtube.com/agodalife Equal Opportunity Employer At Agoda, we pride ourselves on being a company represented by people of all different backgrounds and orientations. We prioritize attracting diverse talent and cultivating an inclusive environment that encourages collaboration and innovation. Employment at Agoda is based solely on a person’s merit and qualifications. We are committed to providing equal employment opportunity regardless of sex, age, race, color, national origin, religion, marital status, pregnancy, sexual orientation, gender identity, disability, citizenship, veteran or military status, and other legally protected characteristics. We will keep your application on file so that we can consider you for future vacancies and you can always ask to have your details removed from the file. For more details please read our privacy policy. Disclaimer We do not accept any terms or conditions, nor do we recognize any agency’s representation of a candidate, from unsolicited third-party or agency submissions. If we receive unsolicited or speculative CVs, we reserve the right to contact and hire the candidate directly without any obligation to pay a recruitment fee.