Fractional MLRO

Fractional MLRO for FCA-Regulated Firms

Exec Capital places fractional MLROs — individuals holding SMF17 FCA approval — into FCA-regulated firms that require a named, approved Money Laundering Reporting Officer but whose financial crime volumes and regulatory complexity do not justify a full-time appointment. The fractional MLRO fulfils the same personal regulatory function as a permanent SMF17 holder: they are the firm’s nominated officer under the Money Laundering Regulations 2017 and the Proceeds of Crime Act 2002, the individual who receives internal suspicious activity reports, decides whether to submit to the National Crime Agency, and is personally accountable to the Board for the firm’s AML and CTF framework. The engagement is structured around days per week rather than a full-time contract — but the regulatory accountability is identical.

If you are a smaller regulated firm that needs a credible, approved MLRO without the cost of a permanent senior hire, or a firm that needs fractional MLRO cover while a permanent appointment works through the FCA approval process, we are happy to discuss your situation directly. Every search is run by our specialist team, with Adrian Lawrence FCA overseeing each mandate.

The same model works outside the Senior Managers and Certification Regime. Payment institutions, e-money institutions, cryptoasset businesses and gambling operators all need a named MLRO or nominated officer under their own rules, even though only some of them have an SMF17. Most of the fractional and outsourced MLRO enquiries we receive come from smaller firms — brokers, IFAs, consumer credit businesses, payment and e-money firms, crypto businesses and gambling operators — that need one experienced person, approved or assessed by their regulator, who is senior enough to own the function but is not needed five days a week. Many also want the same person to hold SMF16 Compliance Oversight, which is why a combined fractional SMF16/17 role is the structure we put in place most often.

How a fractional MLRO search works

A fractional MLRO search follows the same discipline as a permanent senior hire, compressed around the fact that the pool is small and most good candidates already have other clients. We agree the timetable with you at briefing. Regulatory approval or assessment sits with the FCA or the Gambling Commission rather than with us, so we plan the search around it from the first conversation rather than treating it as an afterthought.

If you already know roughly what you need, tell us about your hire and we will start from your brief, or call 0203 834 9616 to talk it through.

Which firms need a fractional MLRO

The fractional MLRO model is most commonly the right answer for three types of regulated firm. First, smaller regulated firms — typically those with modest transaction volumes and limited retail financial crime exposure — where the volume of suspicious activity reporting and the complexity of the AML framework support two to three days per week of MLRO input, or less, rather than a full-time hire. Smaller wealth managers, IFAs and boutique investment firms frequently fall into this category, as do consumer lenders and payment firms operating in narrow segments (payment firms sit outside SMCR but still need an MLRO — see the table below).

Second, firms in the FCA authorisation process that need to name an SMF17 holder as part of their permissions application but are not yet generating sufficient revenue to justify a permanent appointment at the seniority the FCA expects. The fractional MLRO bridges this gap — a credible, approved individual who provides genuine oversight of the developing financial crime framework while the firm establishes its operating volume.

Third, firms running a permanent SMF17 appointment process where the outgoing MLRO has left and the permanent successor has not yet received FCA approval. The fractional arrangement provides approved regulatory coverage during the gap, avoiding the position of having no named SMF17 holder in place. This is distinct from an interim appointment in that the individual may continue on a portfolio basis after the permanent successor is approved, providing continuity support during onboarding. Under the FCA’s temporary cover rule (SUP 10C.3A.6R, as amended by PS26/6 from 24 April 2026), a person can cover an unforeseen SMF vacancy without prior approval, but an application must be submitted within 12 weeks; after that, whoever is in the seat needs approval in their own right.

Two further groups have grown in recent years. Firms under supervisory pressure — where the FCA has raised concerns about financial crime controls, or a voluntary requirement restricts new business until controls are fixed — often need an experienced MLRO with remediation history quickly, and a fractional appointment can be in place faster than a permanent hire. And firms outside SMCR altogether, such as payment and e-money institutions, crypto businesses and gambling operators, need a named MLRO or nominated officer under their own regime and use the fractional model for exactly the same reasons as a small investment firm.

Which firms need an MLRO, and under which regime?

“MLRO” is used loosely. Depending on the firm, it can mean the SMF17 senior manager function under SMCR, the nominated officer and compliance officer required by the Money Laundering Regulations, the person the FCA assesses as responsible for management at a payment firm, or the personal licence holder a gambling operator must appoint. The table sets out who needs what. It is a starting point; your permissions and business model decide the answer, and we check this at briefing.

Three practical points follow from the table. First, at SMCR firms the MLRO is a pre-approved senior manager, so the appointment cannot be finalised until the FCA has approved the individual (or the temporary cover rule applies). Second, at payment and e-money institutions the MLRO is not a senior manager, but the FCA still looks closely at who holds the role, and a weak candidate can hold up an authorisation or a change in control. Third, in crypto and gambling the regulator’s expectations about location and licensing narrow the pool considerably: a fractional MLRO for a crypto firm under the new regime needs to be UK-based, and a fractional MLRO for a gambling operator needs a personal management licence. We screen for these points before you see a CV.

What a fractional MLRO does

A fractional MLRO performs the same substantive functions as a permanent SMF17 holder, structured around the engagement days agreed. In practice this means: acting as the firm’s nominated officer and receiving all internal suspicious activity reports raised by staff; making SAR submission decisions to the National Crime Agency within the required timeframes; overseeing the firm’s transaction monitoring programme and reviewing alerts; maintaining the firm’s AML policies and procedures in line with the JMLSG guidance and the FCA’s expectations; delivering the annual MLRO report to the Board; and managing any FCA interaction on AML matters.

The fractional model requires clear protocols between the MLRO and the firm’s operational staff to ensure that time-sensitive SAR decisions can be escalated and decided regardless of the MLRO’s scheduled engagement days. Where a transaction needs a defence against money laundering (DAML), the firm cannot proceed until the NCA responds or the statutory notice period of seven working days has passed, so a delayed decision by the MLRO delays the customer too. We advise on the design of these protocols as part of the placement to ensure the arrangement works in practice as well as being compliant on paper.

The fractional MLRO is registered with the FCA as the firm’s SMF17 holder. The FCA does not distinguish between full-time and fractional SMF17 holders in terms of the personal accountability that attaches to the designation — the individual is accountable for the firm’s AML framework in full, regardless of how many days per week they are engaged. At payment and e-money institutions, where there is no SMF17, the same individual is registered with the FCA as one of the people responsible for managing the firm, and carries the same practical accountability.

The core duties, day to day

On a typical fractional engagement, the MLRO’s time goes on a fairly consistent set of tasks:

• Business-wide risk assessment. Owning the firm’s assessment of its money laundering and terrorist financing risks, and keeping it current as products, customers and geographies change.
• Policies, controls and procedures. Writing or approving the AML policy, customer due diligence standards, enhanced due diligence triggers and record-keeping rules, and making sure staff actually follow them.
• Customer due diligence oversight. Signing off high-risk and politically exposed customers, reviewing samples of onboarding files and setting the standard for ongoing monitoring.
• Transaction monitoring and screening. Setting rules and thresholds, reviewing alert quality and backlog, and overseeing sanctions screening alongside whoever owns sanctions compliance.
• Internal reports and SARs. Receiving internal reports, documenting decisions, submitting SARs and DAML requests to the NCA, and managing the tipping-off risk that follows.
• Training. Making sure staff are trained on the law and on how to spot and report suspicion, and keeping records that prove it.
• Board reporting. Regular management information and the annual MLRO report, written so the board can understand where the risks are and what is being done.
• Regulator contact. Handling FCA (or Gambling Commission) questions on financial crime, regulatory returns and any review of AML controls.

What stays with the firm is just as important. Day-to-day customer checks, alert triage and record keeping are done by the firm’s own staff; the fractional MLRO designs, oversees and decides. Most firms also name a deputy or alternate who can receive internal reports when the MLRO is unavailable and escalate them. A fractional MLRO who is doing first-line operational work every week is a sign the firm needs more resource beneath the role, not more MLRO days.

Fractional MLRO vs part-time MLRO vs interim MLRO vs outsourced AML consultancy

These four routes are often confused, and they solve different problems. The key distinction is accountability. A fractional, part-time or interim MLRO is an individual who holds the role and the personal responsibility that comes with it. An outsourced AML consultancy can do a great deal of the work, but it cannot hold the role: the MLRO must be a named individual with the authority to act inside your firm.

The terms “outsourced MLRO” and “fractional MLRO” are often used for the same thing: an external individual taking the role for several firms. That is a legitimate model, provided the individual is genuinely the firm’s MLRO — approved or assessed in their own name, with the authority to stop business, direct access to the board and enough time to do the job. Where an “outsourced MLRO” service is really a team of analysts with a senior name on the paperwork, firms should look closely at how decisions are made and documented, because the FCA will.

Other ways to hire an MLRO

This page covers the fractional and outsourced MLRO model. For a permanent appointment, see our MLRO recruitment service. If you want someone embedded on reduced hours, our part-time MLRO page sets out how that works. For full-time cover at short notice, see interim compliance leadership and our urgent SMF appointment service. If the role you need is wider than financial crime, a fractional Chief Compliance Officer may be a better fit. Our guide to permanent, interim and fractional compliance hires compares the options in more depth.

The regulatory position

The FCA’s SMCR framework does not prohibit part-time or portfolio SMF17 holders. The FCA’s expectation is that the individual named in the SMF17 function has sufficient time and resource to fulfil the responsibilities allocated to them in the firm’s Statement of Responsibilities. The regulator’s assessment in any review or enforcement action will focus on whether the MLRO’s availability was demonstrably sufficient for the volume and complexity of the firm’s financial crime activity — not on whether the individual was engaged full-time.

This means the fractional arrangement must be properly designed from the outset. The engagement days must reflect the firm’s actual financial crime volumes, the MLRO’s responsibilities must be clearly documented in the Statement of Responsibilities and the firm’s AML policy framework, and the escalation protocols for time-sensitive SAR decisions must be dependable. A fractional MLRO arrangement that is poorly structured is not a cost-saving — it is a regulatory risk. We build the governance framework around each placement rather than treating the engagement as simply a staffing transaction.

For the approval process for the MLRO function and the wider SMCR framework, see our guide to the FCA Form A approval process.

SMF17 at SMCR firms

At SMCR firms within the scope of the money laundering rules, the MLRO is the SMF17 Money Laundering Reporting Officer function and needs FCA approval before taking up the role. Under section 61 of the Financial Services and Markets Act 2000, the FCA must decide a complete application within three months, with the clock stopping while it waits for information it has asked for. In practice the FCA reported a median of about 25 days for senior manager approvals in 2025/26 — our guide on how long FCA SMF approval takes explains what moves the timetable.

The SMCR is being reformed. Phase 1 changes (PS26/6) came into force on 24 April 2026, including the 12-week rule for submitting an application when someone provides temporary cover. In October 2026 the FCA and PRA consulted on Phase 2 (FCA CP26/37 and PRA CP14/26). The proposals would move several senior manager functions from pre-approval to notification and extend the temporary cover period to 18 weeks, but SMF16 Compliance Oversight and SMF17 MLRO would stay pre-approved. The consultation closes on 22 January 2027. For firms hiring an MLRO, that means approval remains part of the timetable, and fractional candidates who already hold or have held SMF17 elsewhere remain the quickest route.

The MLRs: compliance officer and nominated officer

Separately from SMCR, regulation 21 of the Money Laundering Regulations 2017 requires firms in scope (where appropriate to their size and nature) to appoint a board member or member of senior management as the officer responsible for compliance with the Regulations, and requires every firm in scope to appoint a nominated officer to receive internal reports and decide whether to report to the NCA. The firm must tell its supervisor about either appointment no later than 14 days after it is made. In smaller firms both roles are usually held by the same person, and that person is what most people mean by “the MLRO”. A fractional MLRO typically takes both.

Payment institutions and e-money institutions

Payment and e-money institutions are outside SMCR, so there is no SMF17. They are within the MLRs, however, and must appoint an MLRO and nominated officer. The FCA’s guidance for payment institution applicants says management staff to be registered will usually include the Head of Compliance and/or the MLRO, using the individuals form, and changes to the people responsible for regulated services must be notified in advance. The FCA assesses those individuals as part of authorisation and on any later change. For many smaller payment and e-money firms, a fractional MLRO who has been through the FCA’s questions before is the most practical way to meet that standard. Our payment institution senior hiring page covers the wider leadership team.

Cryptoasset firms

Cryptoasset businesses currently registered with the FCA under the MLRs must appoint an MLRO, and the FCA assesses that person’s fitness and propriety as part of registration. The FCA expects the MLRO to be heavily involved in preparing the application and to stay in place through it, and warns that changing the MLRO can significantly delay an application. The new UK cryptoasset regime comes into force on 25 October 2027, with the FCA’s authorisation window running from 30 September 2026 to 28 February 2027. Under the new regime SMCR applies, and the FCA’s final rules expect the SMF16 and SMF17 holders to be based at the firm’s UK principal place of business. A fractional MLRO for a crypto firm therefore needs to be UK-based, available for the application, and experienced in cryptoasset risks. See our digital assets executive recruitment service for the wider team.

Gambling operators

Casinos are within the MLRs; all gambling licensees are subject to the Proceeds of Crime Act and the Gambling Commission’s licence conditions on money laundering. Since 29 November 2024, all operators except small-scale operators must make sure the person who reports suspected money laundering, and the head of the AML/CTF function, hold a personal management licence. The Commission’s guidance on the standing of the nominated officer also expects sufficient seniority, independence from operational pressure and direct access to the board. A fractional MLRO for a gambling business must hold, or be able to obtain, the licence before taking the role.

Time, seniority and location

Across every regime, the same three expectations come up. The MLRO must have enough authority and independence to challenge the business, including the ability to stop a transaction or a customer relationship. They must have access to the resources and information they need, which in practice means systems access, management information and staff who will escalate to them. And FCA guidance expects a firm’s MLRO to be based in the UK. For a fractional MLRO, the way to show this is in the documents: an engagement letter that sets out days and response times, a log of time spent, board minutes showing the MLRO reporting directly, and a named deputy.

The 2026 changes to the Money Laundering Regulations

The Money Laundering and Terrorist Financing (Amendment) Regulations 2026 were made on 9 June 2026, with most provisions in force from 30 June 2026. They convert many euro thresholds to sterling (for example, the occasional transaction threshold moves from €1,000 to £800 and the €15,000 threshold to £12,000), reword the enhanced due diligence trigger to transactions that are unusually complex or unusually large, replace the high-risk third country test with countries subject to a FATF call for action, and add new requirements on pooled accounts. Rules on cryptoasset correspondent relationships apply from 1 February 2027, and a wider change in control regime for registered firms from 25 October 2027. The amendments do not change the MLRO and nominated officer provisions themselves, but every firm’s policies should have been updated. Reviewing that update is one of the first things a new fractional MLRO should do.

Is a fractional MLRO enough for your firm?

The honest answer depends on volume and risk, not on headcount or turnover alone. A small discretionary wealth manager with a few hundred UK clients and a handful of internal reports a year is a very different proposition from a small payment firm processing cross-border transactions for higher-risk merchants. Before recommending a fractional arrangement we look at:

• Customer risk profile. Proportion of high-risk customers, politically exposed persons, non-UK customers and corporate structures that need enhanced due diligence.
• Products and channels. Cash, cryptoassets, cross-border payments, non-face-to-face onboarding and third-party payments all increase the time the role needs.
• Volumes. Transaction monitoring alerts, internal suspicious activity reports, SARs and DAML requests, and the trend in each.
• The team beneath the MLRO. A fractional MLRO with a capable compliance analyst can cover far more than one working alone.
• Regulatory attention. Open FCA queries, a past review of financial crime controls or an authorisation in progress all call for more days at least for a period.
• Growth plans. A firm that expects to double its customer base in a year should plan the step from fractional to part-time or permanent now.

Signs that a firm has outgrown its fractional MLRO are usually visible in the MI: a growing alert backlog, internal reports waiting days for a decision, policies that have not been reviewed for over a year, or an MLRO who cannot attend board meetings. When that happens the answer is more days, a deputy with real capability, or a move to a part-time or permanent appointment. We would rather tell you that at briefing than place someone into an arrangement that will not last.

What a fractional MLRO typically delivers in the first 90 days

A good fractional MLRO spends the first three months understanding the firm’s real risks, fixing anything urgent and setting up the reporting that lets the board see the function working. A typical plan looks like this:

Days 1–30: understand and stabilise

• Review the business-wide risk assessment, AML policy and procedures against the firm’s actual products and customers, and against the 2026 MLR amendments.
• Take over the internal reporting process, confirm how staff escalate suspicion and set up deputy cover.
• Review open alerts, pending internal reports and any SARs or DAML requests in progress.
• Check the regulator has been told about the appointment (FCA approval or notification, MLR 14-day notification, or PML status for gambling).

Days 31–60: test and prioritise

• Sample-test customer files, especially high-risk and enhanced due diligence cases.
• Review transaction monitoring rules, thresholds and alert quality, and sanctions screening coverage.
• Assess training records and arrange any overdue training.
• Agree a prioritised remediation plan with the CEO and board, with owners and dates.

Days 61–90: report and embed

• Deliver the first MLRO report to the board, with clear management information and the remediation plan.
• Set the standing rhythm: days on site or online, monthly MI, quarterly board reporting, annual report timetable.
• Confirm whether the agreed days are sufficient, and recommend any change in resourcing.

For an authorisation applicant, the first 90 days look different: most of the time goes on the financial crime sections of the application, the risk assessment, policies and procedures, and preparation for FCA questions. That is exactly where an MLRO who has been through the process before earns their fee.

The candidate pool

The pool of experienced, FCA-approved MLROs who are genuinely available for portfolio and fractional work is small and not publicly visible. Most are individuals who have held permanent SMF17 roles at regulated firms and have chosen to move to a portfolio model — either because the variety suits them or because the fractional market compensates them comparably to a single permanent role across their portfolio of engagements. They are not advertising their availability on job boards.

Finding the right fractional MLRO for a specific firm requires understanding which approved individuals are genuinely open to portfolio work, which sectors their experience covers, and whether their current portfolio has capacity for an additional engagement. This is a network access problem, not a search volume problem. Exec Capital’s direct relationships with experienced MLROs operating in the fractional market is the core of what we bring to a fractional placement — alongside the ability to structure the engagement correctly so that it works for both the firm and the individual.

What to look for in a fractional MLRO

• Regulatory history. Current or previous SMF17 or MLRO roles, checked on the FCA register, and how their previous firms fared in FCA reviews.
• Sector match. Payments, crypto, wealth, consumer credit and gambling each have distinct typologies. An MLRO who knows your sector’s risks needs fewer days to be effective.
• Portfolio size and conflicts. How many other firms they serve, how many days those take, and whether any are direct competitors.
• Availability for urgent decisions. How quickly they respond to an internal report or a DAML question on a day they are not scheduled to work.
• Written work. A sample MLRO report or risk assessment (redacted) says more about a candidate than an interview.
• Licensing and location. UK base for FCA firms, a personal management licence for gambling, and the right insurance in place.

We assess these points before shortlisting, and our guide to fitness and propriety sets out what the FCA will look at when it reviews the application.

Combining SMF16 and SMF17 in one fractional role

In smaller firms the same person often holds both SMF16 Compliance Oversight and SMF17 MLRO. The FCA allows this, and for a firm that cannot justify two senior compliance hires it is usually the sensible structure. It also suits the fractional market: many experienced MLROs have a compliance oversight background, and a single fractional holder of both functions gives the board one point of accountability for regulatory compliance and financial crime.

The combination works best where the firm’s compliance and financial crime risks are both moderate, the business model is not changing fast, and the individual has real depth in both areas rather than one. It works less well where conduct risk and financial crime risk are both high — a consumer lender with a large vulnerable customer base and online onboarding, for example — or where the volume of work in either function would take most of the agreed days on its own. Our guide to SMF16 vs SMF17 covers the decision, and our fractional compliance officer service places combined SMF16/17 holders.

Engagement structures and fees

Fractional MLRO arrangements are typically structured on a retained days-per-month basis, with a defined minimum engagement and a clear scope of responsibilities agreed upfront. Day rates for experienced, FCA-approved SMF17 holders operating in the fractional market reflect the personal liability exposure the role carries, the scarcity of the approved candidate pool, the sector and the complexity of the firm. We discuss realistic rates for your firm at briefing rather than publishing a range that may not fit your situation.

Our fee structure is agreed with you at briefing. Where the MLRO is engaged through us on a day rate, the day rate we quote includes our fee. Where you prefer to engage the individual directly, or are making a permanent or part-time appointment, we agree the basis with you before the search starts. Our guide to retained and contingent executive search explains the difference between the two main approaches.

Whatever the basis, the engagement should cover: the number of days and how they are scheduled; response times for urgent internal reports and DAML decisions outside those days; deputy and holiday cover; access to systems and information; reporting lines to the board; notice periods on both sides, with enough time to find and approve a successor; and professional indemnity and directors’ and officers’ insurance. Most fractional MLROs work through their own company, so the IR35 status of the engagement also needs to be assessed — see our guide to IR35 for senior executive engagements.

Who we place fractional MLROs for

Most of our fractional MLRO and combined SMF16/17 work is for smaller regulated firms that need senior financial crime leadership without a full-time salary. Typical clients include:

• Small brokers and IFAs within the scope of the MLRs, often looking for a combined compliance and MLRO holder.
• Wealth managers and investment firms, including boutique discretionary managers and advisory firms — see our wealth management recruitment work.
• Consumer credit firms and specialist lenders with growing customer books and online onboarding.
• Payment institutions and e-money institutions, from authorisation applicants to growing firms adding new corridors or products.
• Cryptoasset businesses moving from MLR registration to authorisation under the new regime.
• Gambling operators, particularly smaller remote operators that need a licensed nominated officer.
• Fintechs and start-ups in authorisation that need a credible MLRO named in their application — see our fintech recruitment page.

We work with founders, CEOs, compliance directors, boards and investors. If you are building a regulated business from scratch, our guide to building your SMF team for authorisation covers the wider team.

Working with Exec Capital on a fractional MLRO placement

Every fractional MLRO search is run by our specialist team, with Adrian Lawrence FCA overseeing each mandate. The combination of network access to approved SMF17 holders who are genuinely open to portfolio work, regulatory understanding of how to structure the engagement correctly, and direct experience of the FCA’s expectations for the function means that our approach to fractional MLRO placements is substantively different from a standard compliance staffing exercise.

We begin each fractional MLRO mandate with a structured conversation about the firm’s permission set, its AML framework maturity, its financial crime volumes, and the engagement structure that would be appropriate. This frequently takes thirty minutes and immediately clarifies whether a fractional model is genuinely viable for the firm or whether the compliance complexity warrants a permanent appointment. There is no charge for this initial conversation.

For the permanent SMF17 appointment, see our MLRO Recruitment (SMF17) page. For the compliance function that frequently sits alongside the MLRO at smaller firms, see our SMF16 Head of Compliance Recruitment page. For the broader fractional compliance model, see our Fractional Compliance Officer page.

To start, contact us or call 0203 834 9616. Tell us your permissions, your regulator, your timing and whether you also need SMF16 cover, and we will tell you honestly whether a fractional MLRO is the right answer.

Frequently asked questions

What is a fractional MLRO?

A fractional MLRO is an experienced Money Laundering Reporting Officer who takes the role at your firm for a set number of days, usually alongside a small number of other firms. They hold the role and its personal accountability in full — as SMF17 at an SMCR firm, or as the MLRs nominated officer at a payment, e-money, crypto or gambling business.

Is an outsourced MLRO allowed?

An external individual can be your MLRO, and many smaller firms work this way. What cannot be outsourced is the accountability: the MLRO must be a named individual, approved or assessed in their own name, with the authority, independence, information and time to do the job. Firms can outsource supporting tasks, but not the role itself.

How many days a month does a fractional MLRO work?

It depends on customer risk, products and volumes. Some small, low-risk firms need a few days a month; payment, crypto and higher-risk firms often need two or three days a week. We set the days at briefing and recommend reviewing them after the first 90 days.

Does a fractional MLRO need FCA approval?

At SMCR firms, yes: the MLRO is SMF17 and needs pre-approval, and the Phase 2 proposals keep it that way. At payment and e-money institutions the MLRO is not an SMF but is registered and assessed by the FCA. Crypto firms’ MLROs are assessed at registration, and gambling operators’ nominated officers need a personal management licence.

Can one person be our SMF16 and SMF17?

Yes. Combining Compliance Oversight and MLRO in one fractional holder is common in smaller firms and is often the most efficient structure, provided the individual has depth in both areas and enough days to cover both.

How long does FCA approval take for a fractional MLRO?

The FCA must decide a complete application within three months. Its reported median for senior manager approvals in 2025/26 was about 25 days. Incomplete applications and follow-up questions add time, so a well-prepared Form A matters.

Can a fractional MLRO be based outside the UK?

For FCA-regulated firms, FCA guidance expects the MLRO to be based in the UK, and under the new cryptoasset regime the SMF16 and SMF17 holders are expected to be based at the firm’s UK principal place of business. We only shortlist UK-based candidates for these roles.

What is the difference between a fractional and a part-time MLRO?

A fractional MLRO usually serves several firms on a set number of days each. A part-time MLRO is typically embedded with one firm on reduced hours. Both hold the role in full. If you want an embedded hire, the part-time route linked in “Other ways to hire an MLRO” above is the better fit.

How much does a fractional MLRO cost?

Fractional MLROs work on a day rate that reflects seniority, sector and the liability the role carries. The total cost depends on the days you need. We give you realistic figures at briefing, and where the MLRO is engaged through us the day rate includes our fee. Our SMF salary guide covers permanent pay for comparison.

Can a fractional MLRO support our authorisation application?

Yes, and it is one of the most common reasons firms hire one. The MLRO should be named early, help write the financial crime sections of the application and stay through the FCA’s questions. Changing MLRO mid-application can cause delay.

For MLROs interested in fractional work

If you hold or have held SMF17, or an MLRO or nominated officer role at a payment, crypto or gambling business, and have capacity for a fractional engagement, please register with us and see our current opportunities. Tell us your sectors, your current portfolio and the days you have available.

Further reading

For the permanent MLRO appointment, see our SMF17 MLRO hiring guide and our guide to when a firm needs a fractional MLRO. For the compliance function that typically sits alongside or combines with the MLRO at Core firms, see our SMF16 Head of Compliance hiring guide and our guide to dual SMF holders at smaller regulated firms.

For the broader SMF framework, see our SMF Roles guide. For the FCA’s SMCR overview and the JMLSG guidance that defines the standard the MLRO is expected to implement, see the FCA’s SMCR overview and the Joint Money Laundering Steering Group guidance. If the FCA is already asking questions about your financial crime controls, our guide to interim SMF16 and SMF17 cover during FCA supervision explains the options.