MLRO recruitment for FCA-regulated firms
MLRO Capital finds money laundering reporting officers, deputy MLROs and financial crime leaders, permanent, interim and fractional. Every search runs through our specialist practice SMF Capital and is led personally by Adrian Lawrence FCA.
- SMF17 and MLR-only firms
- Fractional from one day a week
- Interim cover at short notice
- Fit and proper built in
The appointment with personal criminal liability
The money laundering reporting officer is unlike any other senior hire. At firms within the Senior Managers regime the role is a Senior Manager Function, SMF17, which the FCA must approve before the person starts. The MLRO is usually also the firm’s nominated officer under the Money Laundering Regulations 2017, the person who receives internal suspicious activity reports and decides whether to report to the National Crime Agency.
That second role carries personal criminal exposure. Under the Proceeds of Crime Act 2002, a nominated officer in the regulated sector who fails to make a required disclosure can commit an offence in their own right. No other Senior Manager carries quite the same combination of regulatory accountability and personal criminal liability, and good candidates know it. They look hard at the firm before they accept.
Firms authorised only as payment or e-money institutions sit outside the Senior Managers regime, but they still need an MLRO under the Money Laundering Regulations, and the FCA still assesses that person closely. Crypto-asset firms moving from registration to full authorisation face the same scrutiny with more at stake. We recruit for all of them.
What an MLRO is accountable for
- Oversight of anti-money laundering systems and controls, under the FCA’s SYSC 6.3 rules
- The business-wide risk assessment and the policies that follow from it
- Customer due diligence and enhanced due diligence standards
- Receiving internal reports and deciding on suspicious activity reports
- Sanctions screening and the response to new designations
- The annual MLRO report to the board and its recommendations
- Training, and the firm’s relationship with the FCA and the NCA
MLRO searches we run
Four practice areas cover the MLRO and financial crime hires firms make. Every MLRO search is led personally by Adrian Lawrence FCA
Permanent MLRO
SMF17 holders and MLROs matched to your sector’s financial crime risks, from first appointment to Enhanced firms.
SMF16 and SMF17 explained →
Fractional MLRO
Experienced, approvable MLROs working one to three days a week for smaller firms that need accountable oversight.
When fractional works →
Interim and urgent cover
Interim MLROs for vacancies, remediation programmes and skilled person reviews, shortlisted in days.
The 12-week rule →
Financial crime team
Heads of financial crime, deputy MLROs, sanctions leads and the investigators and analysts around your MLRO.
Sizing the team →
Every MLRO search is led personally by Adrian Lawrence FCA
An MLRO who knows your risks
Financial crime experience is not one portable credential. An MLRO from a retail bank is not automatically ready for a crypto-asset firm, and a wealth manager’s MLRO may never have dealt with payment fraud at volume. We specify every search against the risks your firm actually carries.
Payments and e-money
MLROs for payment and e-money institutions, where transaction monitoring, safeguarding and fraud sit close to the money laundering risk, and the FCA’s scrutiny of the MLRO is intense.
Payments and fintechCrypto-asset firms
MLROs with Travel Rule and blockchain analytics experience for firms moving from registration to full authorisation, where the people named in the application matter most.
Hiring a crypto MLROWealth and investment
MLROs for wealth managers, advice firms and investment managers, comfortable with source of wealth, politically exposed persons and complex ownership structures.
Wealth and adviceConsumer credit and brokers
MLROs for lenders, credit brokers and debt businesses, often combined with compliance oversight, where fraud and affordability sit alongside money laundering risk.
Consumer creditInsurance
MLROs for life insurers, brokers and MGAs, where the money laundering regime applies to some products and not others, and the role is usually combined with wider compliance.
InsuranceBanks and building societies
SMF17 holders for smaller banks, specialist lenders and building societies, with the depth to lead a team and stand behind the firm’s controls under PRA and FCA oversight.
Banks and building societiesWhat separates a strong MLRO candidate
The FCA’s Financial Crime Guide and the industry guidance published by the Joint Money Laundering Steering Group describe what good anti-money laundering controls look like. Our job is to find the person who can build and defend them at your firm. In every MLRO search we test for:
Independence and standing
The regulator looks for MLROs who can show they have challenged the business, escalated concerns and recorded what they did. We ask candidates for specific examples, not general statements, and we check them against references.
Judgement on reporting
Deciding whether to make a suspicious activity report is the MLRO’s personal call. We explore how candidates have handled borderline decisions, how they document their reasoning, and how they have dealt with pressure from the front office.
Sector-matched risk experience
We match candidates on the financial crime risks they have actually managed: payments fraud, sanctions exposure, source of wealth, trade-based risk or crypto-asset flows, rather than on years of seniority alone.
Readiness for approval
For SMF17 roles we test candidates against the fit and proper test before they reach your shortlist, and request regulatory references early.
Typical MLRO rates and salaries
Rates depend on the firm’s sector, size and risk profile, and on whether the MLRO also holds compliance oversight. As a guide, FD Capital’s SMCR compliance recruitment data puts experienced fractional MLROs at £600 to £1,100 a day and permanent SMF17 salaries at around £90,000 to £150,000. Our full SMF and compliance salary guide breaks this down by firm type.
From first call to an approved MLRO
A short call is enough to start. Tell us the firm, its permissions and your timing.
- Brief against your risk assessment
We start from your business-wide risk assessment, your permissions and the responsibilities the MLRO will sign, so the specification reflects the risks the role actually manages.
- Targeted, confidential search
Most strong MLROs are not job-hunting. We approach them directly, without naming your firm until the right point, drawing on a network pooled across all five FD Capital Group practices.
- Fit and proper and reporting judgement
Before anyone reaches your shortlist we test regulatory readiness and explore how they have handled real reporting decisions.
- Shortlist and interviews
You meet a small number of candidates. Adrian Lawrence FCA interviews every shortlisted MLRO candidate personally. Our guide to interviewing an SMF candidate sets out the questions that reveal readiness.
- References, approval and handover
We request regulatory references early, help prepare the Statement of Responsibilities and stay involved until the MLRO is approved and in post.
Part of a specialist recruitment network
MLRO Capital is part of FD Capital Group. When the hire around your MLRO isn’t a financial crime role, the right practice takes it. Every search is led personally by Adrian Lawrence FCA
SMF Capital
Every Senior Manager Function, from compliance oversight to the chief executive and chair.
SMF designations guide →
FD Capital
Fractional, interim and permanent finance directors, and compliance hires at operator level.
SMF2 CFO recruitment →
Exec Capital
C-suite and board-level executive search, including chief risk and chief operating officers at regulated firms.
FCA-regulated executive search →
NED Capital
Independent non-executives and committee chairs who hold the board’s oversight of financial crime.
Board skills matrix →
Every search is led personally by Adrian Lawrence FCA
MLROs and financial crime professionals
If you hold SMF17, act as nominated officer at a payments, e-money or crypto-asset firm, or lead a financial crime team and are ready for your first MLRO appointment, we want to hear from you. We are particularly interested in experienced MLROs open to fractional or interim work across more than one firm.
Current roles are listed on the SMF Capital jobs board. Registration is confidential, covers every FD Capital Group practice, and we never share your details with a firm without speaking to you first. Check your current approvals on the FCA Financial Services Register.
What we want to hear about
- Your current approvals, including SMF17 or nominated officer roles
- The sectors and financial crime risks you have managed
- Reporting decisions and remediation work you have led
- Whether you are open to fractional, interim or permanent work
- Your notice period and any day rate or salary expectations
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Read articleFrequently asked questions
Is the MLRO always a Senior Manager Function?
Only at firms within the Senior Managers regime, where it is SMF17 and needs FCA approval. Firms authorised solely as payment or e-money institutions, and some other firms covered by the Money Laundering Regulations, still need an MLRO and a nominated officer but are outside the regime. The FCA still assesses those individuals closely.
Can our MLRO be part-time or external?
Yes. Many smaller firms appoint a fractional MLRO who works a set number of days a month and is approved at the firm. What you cannot do is outsource the accountability: the MLRO must be a named individual with the authority, independence and resources to do the job. See fractional MLRO recruitment.
Can one person be both compliance officer and MLRO?
Often, yes, particularly at smaller firms. Larger or higher-risk firms usually split the roles as they grow. Our article on when to split a combined SMF16/17 role sets out the signs, and our combined role recruitment page explains how we search for both.
Do we need a deputy MLRO?
Every firm needs a plan for when the MLRO is absent, because suspicious activity reporting cannot wait. Larger firms usually appoint a deputy; smaller firms often arrange cover. Read do you need a deputy MLRO?
Our MLRO has resigned. What now?
Arrange cover immediately, because the nominated officer role cannot sit empty. Under the 12-week rule, someone can perform SMF17 temporarily while you apply for the permanent holder. We can place an interim MLRO quickly and run the permanent search alongside. See urgent SMF replacement.
Need an MLRO, permanent, interim or fractional?
Tell us about the firm, its permissions and your timing. SMF Capital will come back to you the same working day, with the fit and proper assessment built into the search from the first conversation.