Exec Capital recruits Money Laundering Reporting Officers for FCA-regulated businesses, financial services firms and corporate groups across the UK. Permanent, interim, fractional and part-time MLRO recruitment — including combined SMF16/SMF17 compliance and MLRO appointments for smaller firms.
Call 0203 834 9616 — or tell us about your hire and we will come back to you to agree the brief and timetable.
Short answer
MLRO recruitment is the search for the person who owns a firm’s anti-money laundering framework and decides which suspicions are reported to the National Crime Agency. At most Core and Enhanced SMCR firms that person holds the SMF17 function and needs FCA approval before taking it up; payment and e-money institutions sit outside SMCR and appoint their MLRO under regulation 21 of the Money Laundering Regulations. Exec Capital fills the role on a permanent, interim, fractional or part-time basis, including combined SMF16/SMF17 appointments.
Need an MLRO without a full-time hire?
Most of the MLRO enquiries we receive are not for a full-time permanent hire. Smaller authorised firms, start-ups going through authorisation and payment businesses often need an experienced MLRO for one or two days a week, or a combined compliance officer and MLRO who can hold both SMF16 and SMF17. The quickest routes are:
- Fractional MLRO — an experienced, approvable MLRO working a set number of days a month on an ongoing basis.
- Part-time MLRO — a regular weekly commitment, often two or three days, for firms with steady SAR and monitoring volumes.
- Fractional compliance officer — a combined SMF16/SMF17 holder who covers compliance oversight and money laundering reporting together.
- Urgent SMF appointment — when an MLRO or compliance officer has left and the temporary cover clock is running.
This page covers MLRO recruitment as a whole, with most of the detail on permanent appointments and on choosing the right format. If you already know you need a fractional or interim arrangement, the pages above go into those formats in more depth.
What Is an MLRO?
A Money Laundering Reporting Officer (MLRO) — also known as a Nominated Officer — is the senior individual within a regulated business who holds personal accountability for the firm’s anti-money laundering (AML) and counter-terrorist financing (CTF) framework. The MLRO is the firm’s principal point of contact with the National Crime Agency (NCA) for Suspicious Activity Reports (SARs), accountable to the regulator for the quality of the firm’s financial crime controls, and responsible for ensuring the business meets its obligations under the Proceeds of Crime Act 2002 and the Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017.
In Core and Enhanced firms under the Senior Managers & Certification Regime (SMCR) that are subject to the FCA’s money laundering systems and controls rules, the MLRO holds the SMF17 (Money Laundering Reporting Officer) Senior Management Function. This designation carries personal regulatory accountability to the FCA — meaning the individual MLRO can face direct regulatory sanctions, including financial penalties and prohibition from working in financial services, if the firm’s AML framework is found to be inadequate on their watch. This level of personal accountability makes the MLRO appointment one of the most consequential and legally sensitive hiring decisions a regulated business makes.
Not every regulated firm sits inside SMCR. Authorised payment institutions and e-money institutions whose only regulated status comes from the Payment Services Regulations 2017 or the Electronic Money Regulations 2011 are outside the regime, so they have no SMF17. They still have to appoint a nominated officer, and where appropriate to their size and nature a board-level officer responsible for compliance with the Money Laundering Regulations, under regulation 21 of the MLRs. In practice the person is usually called the MLRO, and the FCA looks hard at their competence when it assesses the firm’s management. Most Limited Scope SMCR firms, such as limited permission consumer credit firms, do not have an SMF17 requirement either, although any of them that fall within the MLRs still need a nominated officer.
Outside FCA-regulated financial services, organisations subject to the Money Laundering Regulations — including accountancy practices, legal firms, estate agents, high-value dealers and trust or company service providers — must also appoint a Nominated Officer with equivalent MLRO responsibilities. The scope and seniority of these roles varies by firm size and risk profile, but the core legal accountability is consistent across all regulated sectors.
| MLRO / Nominated Officer | Deputy MLRO | Head of Financial Crime |
|---|---|---|
| Personal SMF17 accountability to FCA (SMCR firms); regulation 21 appointment at payment and e-money firms | Covers MLRO absence, no SMF17 designation | Operational financial crime leadership |
| Receives and makes all SAR decisions | Supports SAR process and AML operations | Manages AML team and controls |
| Board-level or direct CEO report | Reports to MLRO | Reports to MLRO or CCO |
| FCA approval required where SMF17 applies | No FCA approval required | No FCA approval required |
| Highest package of the three, reflecting personal accountability | Typically a step below the MLRO | Varies with team size and scope |
For a fuller breakdown of the role, see our MLRO job description and the SMF17 MLRO hiring guide.
How MLRO recruitment works
Every MLRO search follows the same core stages, whether the end result is a permanent SMF17 holder, an interim covering a gap or a fractional MLRO working two days a month. What changes is the pace and the depth of each stage. We agree the timetable with you at briefing, taking account of any regulatory deadline you are working to.
| Stage | What happens |
|---|---|
| 1. Brief | We take the brief from the CEO, chair or compliance lead: the firm’s permissions and SMCR category (or payment/e-money status), the AML risk profile, whether SMF16 is combined, the format (permanent, interim, fractional, part-time) and any FCA deadline. |
| 2. Search | Our team approaches active and passive MLROs, deputy MLROs and financial crime leaders with relevant sector and typology experience, drawing on the group’s regulated-sector network. |
| 3. Shortlist | You receive a shortlist with written notes on each candidate’s AML experience, SMF history, regulatory engagement, availability and likely fitness and propriety position. |
| 4. Interviews | We arrange interviews, help you structure technical questions (risk assessment, SAR decisions, FCA engagement) and gather feedback on both sides. |
| 5. Offer | We manage the offer or day-rate agreement, notice periods and any conditions linked to FCA approval. |
| 6. Onboarding | We support the Form A or notification process, regulatory references and handover planning so the new MLRO can start well. |
For the regulatory side of the process, our guides on the FCA Form A approval process and fitness and propriety explain what the firm will need to submit and what the FCA tests.
Compensation and Package Structure
MLRO compensation varies significantly by sector, business size, regulatory complexity, and whether the role is standalone or combined with broader compliance or CCO responsibilities. Rather than publish ranges we cannot source, the table below shows how the package tends to move across the main types of MLRO appointment. For current figures on senior manager pay, see our SMF salary guide.
| Role Type | Business Context | How the package is shaped |
|---|---|---|
| MLRO — Tier 1 bank or large FCA firm | High-volume SAR programme, 500+ staff | Top of the market; large financial crime team, significant variable pay and deferral under remuneration rules |
| MLRO — mid-market financial services | Asset manager, insurer, payments firm | Strong base with bonus; premium for complex or cross-border risk |
| MLRO — smaller FCA-authorised firm | Consumer credit, e-money, smaller broker | Often part-time or fractional; full-time salaries lower than mid-market |
| MLRO / Nominated Officer — non-finance | Legal, accountancy, estate agency, TCSP | Frequently combined with a partner, director or risk role |
| Interim MLRO — day rate | Urgent cover, remediation, SMF17 gap | Day rate, higher where remediation or a skilled person review is under way |
| MLRO — combined with CCO or compliance | Smaller firm, dual SMF16 / SMF17 holder | Premium over a single-function role for the extra accountability |
Bonus, pension and benefits sit on top of base salary. Interim MLRO day rates in regulatory remediation contexts — particularly where the firm is subject to a Section 166 skilled person review or NCA investigation — tend to sit at the upper end of the market. In some smaller FCA-regulated firms, the MLRO function is combined with the SMF16 Compliance Oversight function and held by a single individual — a dual-hat arrangement that typically commands a premium above the single-function rate. The FCA’s financial crime guidance sets the regulatory expectations that inform what the market pays for MLRO-calibre candidates.
Three structural points matter more than the headline number. First, at banks and other firms within the remuneration codes, variable pay for senior managers is subject to deferral and malus and clawback; the bonus cap was removed from 31 October 2023, and the FCA (PS25/15) and PRA (PS21/25) have since eased deferral rules, so the shape of the package is changing. Second, the MLRO must be paid in a way that does not compromise their independence — bonus tied to revenue or onboarding volumes is a poor look for the person who can refuse business. Third, interim and fractional MLROs are engaged on a day rate, which includes our fee, so the firm sees one all-in cost.
Hiring an MLRO — full-time, fractional or interim?
We find approvable SMF17 holders and regulation 21 MLROs for authorised firms, payment businesses and e-money institutions, including combined SMF16/SMF17 compliance officers. Call 0203 834 9616 or contact us.
When Do Businesses Need to Recruit an MLRO?
FCA Authorisation — SMCR SMF17 Requirement
Every Core or Enhanced SMCR firm that is subject to the FCA’s anti-money laundering systems and controls rules must have a named individual approved by the FCA to hold the SMF17 Money Laundering Reporting Officer function. This is a mandatory regulatory requirement — not a best practice recommendation — and a firm in scope cannot run without someone responsible for it. For businesses seeking FCA authorisation for the first time, recruiting a qualified MLRO before the authorisation application is a critical step. The FCA’s assessment of the proposed MLRO’s fitness and propriety — their knowledge, skills, experience and integrity — is a central element of the authorisation process. An MLRO who cannot satisfy this assessment will delay or prevent the firm’s authorisation. Our guide to building an SMF team from scratch covers the wider picture.
Departure of an Existing MLRO
The departure of an MLRO creates an immediate and serious regulatory gap. The firm must tell the FCA that the SMF17 holder has left and put cover in place. Since the SMCR Phase 1 changes came into force in April 2026, SUP 10C.3A.6R allows another person to cover an unexpected or temporary absence without approval, but the firm must submit an application for a permanent replacement within 12 weeks; the regulators’ October 2026 consultations (FCA CP26/37 and PRA CP14/26) propose extending that to 18 weeks. An interim MLRO can be appointed to cover the vacancy while a permanent search proceeds. See our guide to interim SMF16 and SMF17 cover for the detail.
Regulatory Investigation or AML Remediation
When a firm receives FCA supervisory attention relating to its financial crime controls — whether through a Section 166 skilled person review, a Dear CEO letter identifying AML weaknesses, or direct supervisory engagement — the board typically needs to demonstrate to the regulator that the MLRO function is under credible, experienced leadership. Where the existing MLRO’s capability is part of the supervisory concern, replacing them with a more experienced individual is often the single most effective signal the firm can send to the regulator that it is taking the remediation seriously. Interim MLROs with specific AML remediation experience are deployed regularly in exactly this context.
Business Growth and Increased AML Risk Exposure
As regulated businesses scale — increasing customer volumes, entering new markets, launching new products or acquiring other businesses — their AML risk exposure grows in ways that frequently exceed the capability of the existing MLRO to manage alone. A consumer credit firm that doubles its customer base, a payment institution that launches cross-border transfer services, or an asset manager that begins servicing higher-risk geographies may find that the MLRO who was adequate at an earlier stage of the business is no longer sufficient for the current risk profile. Recruiting a more experienced MLRO — or appointing a Deputy MLRO to provide additional capacity — is the appropriate response before the risk profile grows beyond the framework’s ability to manage it.
New Product Lines and High-Risk Client Categories
Regulated businesses that introduce products or services that carry elevated financial crime risk — correspondent banking, wealth management for politically exposed persons (PEPs), cryptocurrency services, or trade finance — typically need an MLRO with specific experience of the relevant risk typology. The FCA’s Financial Crime Guide identifies specific high-risk product categories and the enhanced due diligence obligations they attract. An MLRO without experience of these typologies is unlikely to satisfy the regulator’s expectations or the firm’s own risk appetite when operating in these areas.
M&A and Business Acquisition
When a regulated business acquires another firm, the MLRO function of the acquiring business typically extends to cover the acquired entity until a permanent structure is established. Where the acquired firm had its own MLRO with their own FCA approval, the post-acquisition integration requires a clear plan for the combined MLRO structure — who holds the SMF17 function, over which legal entities, and with what scope of accountability. Interim or additional MLRO capacity is frequently required during this transition. See also our CCO recruitment practice for the broader compliance leadership dimension of regulated business M&A.
MLROs for payment and e-money institutions
Payment and e-money firms are one of the largest sources of MLRO demand, and they are often the most confused about what the role requires. Because authorised payment institutions and e-money institutions are regulated under the Payment Services Regulations 2017 and the Electronic Money Regulations 2011 rather than through a Part 4A permission, SMCR does not apply to them. There is no SMF17, no Form A for the MLRO and no Statement of Responsibilities.
That does not make the role lighter. Under regulation 21 of the Money Laundering Regulations the firm must appoint a nominated officer to receive internal disclosures and report to the NCA, and, where appropriate to its size and nature, a board member or member of senior management as the officer responsible for compliance with the MLRs. Most payment firms combine these in one MLRO. The FCA assesses the people responsible for managing a payment or e-money institution as part of authorisation and expects to be told about changes, so an MLRO without relevant payments experience can still hold up an application or attract supervisory attention later.
The skills payment firms need are specific: transaction monitoring at volume, mule account detection, authorised push payment fraud, cross-border and correspondent risk, agent and distributor oversight and, for e-money, safeguarding interplay with financial crime controls. Many payment firms start with a fractional MLRO and move to a full-time appointment as volumes grow. Our guide to senior hiring at payment institutions and the fintech recruitment page cover the wider leadership team.
A payment or e-money firm that later applies for a banking licence, or adds a Part 4A permission, will come into SMCR at that point and will need an approved SMF17. If that move is on the roadmap, it is worth hiring an MLRO now who would be approvable as an SMF17 later, rather than building the function around someone who would need to be replaced.
Permanent, interim, fractional or part-time: choosing the MLRO format
The MLRO title is the same in each case; the commitment, cost and use case are not. The table sets out the four formats we recruit for.
| Format | Typical commitment | Best suited to | How it is paid |
|---|---|---|---|
| Permanent MLRO (this page) | Full-time employee | Larger firms, high SAR volumes, complex or higher-risk business | Salary, bonus and benefits; search fee agreed at briefing |
| Interim MLRO | Full-time or near full-time for a fixed period | Sudden departure, remediation, skilled person review, parental leave | Day rate, including our fee |
| Fractional MLRO | A set number of days a month, ongoing | Smaller authorised firms, payment and e-money start-ups, firms in authorisation | Day rate, including our fee |
| Part-time MLRO | Two or three days a week | Steady volumes that need regular presence but not a full-time salary | Day rate or part-time salary |
| Combined SMF16/SMF17 | Any of the above | Smaller firms where one person can credibly run compliance and AML | As per format |
A fractional or part-time MLRO must still have enough time to do the job. The FCA expects the MLRO to have adequate resources and authority, and a few days a month only works where SAR volumes and the risk profile are modest and the firm has good first-line controls. Our fractional MLRO guide and the comparison of permanent, interim and fractional compliance hires help firms decide.
Other ways to hire an MLRO: for an ongoing arrangement of a few days a month, see fractional MLRO; for a regular weekly commitment, part-time MLRO; for a combined compliance and MLRO role, fractional compliance officer or fractional CCO; and for a departure that needs cover now, urgent SMF appointment.
What an MLRO Does
AML and CTF Framework Ownership
Developing and maintaining the firm’s anti-money laundering and counter-terrorist financing framework — the policies, procedures, controls, risk assessments, customer due diligence standards and monitoring systems that together constitute the firm’s financial crime defence. The MLRO is accountable for the quality and effectiveness of this framework, not just its existence. The FATF’s Recommendations and the FCA’s financial crime guidance set the international and domestic standards against which this framework is assessed by regulators and external reviewers.
Suspicious Activity Reporting
Receiving, reviewing and making consent decisions on internal Suspicious Activity Reports (SARs) submitted by staff across the business. Where the MLRO determines that a SAR should be submitted externally, they file the report with the NCA’s Suspicious Activity Reports regime under the Proceeds of Crime Act 2002. This responsibility carries direct criminal liability — a nominated officer who fails to pass on a disclosure where they know or suspect, or have reasonable grounds to know or suspect, money laundering commits a criminal offence personally. The quality and timeliness of the firm’s SAR submissions is a key indicator of AML framework effectiveness that regulators monitor.
Customer Due Diligence and Know Your Customer
Setting the standards for customer due diligence (CDD) and enhanced due diligence (EDD) across the business — determining the risk-based approach to customer onboarding, ongoing monitoring and periodic review. This includes setting the firm’s PEP and sanctions screening standards, establishing the enhanced due diligence requirements for high-risk customers and relationships, and ensuring the business’s know-your-customer (KYC) processes meet the standards required by the Money Laundering Regulations and the FCA’s expectations under the Joint Money Laundering Steering Group (JMLSG) guidance.
AML Risk Assessment
Conducting and maintaining the firm’s AML risk assessment — the documented analysis of the money laundering and terrorist financing risks the business faces given its products, services, customers, delivery channels and geographies. The Money Laundering Regulations require all regulated businesses to conduct a documented risk assessment and to keep it current as the business evolves. The MLRO owns this assessment and ensures it drives the proportionate application of controls across the business — focusing enhanced measures where risk is highest, not applying a uniform approach that fails both regulators and commercial efficiency.
FCA Relationship and Regulatory Engagement
Managing the firm’s relationship with the FCA on financial crime matters — responding to supervisory information requests, participating in FCA thematic reviews, and engaging proactively with the regulator where material AML matters arise. In firms subject to enhanced FCA supervision, the MLRO may have direct contact with their FCA supervisor and should have the seniority and confidence to engage the regulator independently and effectively. The MLRO’s ability to communicate credibly with regulators is one of the most important capabilities the firm relies on in any period of supervisory attention.
Staff Training and AML Culture
Designing and overseeing the firm’s AML training programme — ensuring that all relevant staff understand their obligations under the Proceeds of Crime Act, can recognise the signs of money laundering in the context of their specific roles, know how to submit internal SARs, and understand the personal criminal liability they face if they fail to report. The MLRO is also responsible for fostering the culture of financial crime awareness across the business — the environment in which staff feel empowered to raise concerns, rather than suppressing suspicion out of commercial pressure or fear of client relations implications.
Sanctions Compliance
Overseeing the firm’s compliance with UK financial sanctions administered by the Office of Financial Sanctions Implementation (OFSI) and, where applicable, US OFAC sanctions for firms with US nexus. This includes maintaining the firm’s sanctions screening programme, managing sanctions alerts and escalations, ensuring the business can demonstrate compliance with its sanctions obligations to regulators and counterparties, and responding promptly to new sanctions designations as they are issued. The proliferation of sanctions programmes since 2022 has significantly increased the technical complexity and operational demands of sanctions compliance for most regulated businesses.
Board and Audit Committee Reporting
Preparing and presenting the firm’s financial crime risk report to the board and audit committee — providing directors and NEDs with an accurate picture of the AML risk profile, SAR statistics, CDD completion rates, training compliance, and the status of any regulatory concerns or remediation programmes. The UK Corporate Governance Code and FCA’s SMCR requirements together create board-level accountability for financial crime governance — the MLRO is the executive through whom that accountability is exercised and evidenced. FCA rules also require the MLRO to report to the governing body at least annually on the operation and effectiveness of the firm’s anti-money laundering systems and controls.
What a new MLRO typically delivers in the first 90 days
A good MLRO appointment shows in the first three months. The order varies with the firm’s position — a firm under a skilled person review has different priorities from a start-up going through authorisation — but the shape is usually similar.
Days 1–30: understand the risk and the backlog
- Read the business-wide risk assessment, policies, the last annual MLRO report, internal audit findings and any FCA correspondence.
- Review open internal SARs, pending NCA reports, alert backlogs in transaction monitoring and sanctions screening, and overdue periodic reviews.
- Meet the CEO, chair, audit or risk committee chair and first-line heads to understand appetite, products and pressure points.
- Confirm the regulatory position: SMF17 approval or temporary cover, Statement of Responsibilities, or the regulation 21 appointment and notifications for a payment or e-money firm.
Days 31–60: fix what is urgent
- Clear or triage backlogs and set realistic service levels for alert and SAR handling.
- Correct the obvious gaps in CDD, EDD and PEP handling, and update the risk assessment where it no longer reflects the business.
- Agree management information the board will see each quarter: SAR numbers and timeliness, CDD completion, alert ageing, training completion, open audit points.
- Check whether the MLRO function has enough people and system support, and say so plainly if it does not.
Days 61–90: set the plan
- Present a financial crime improvement plan to the board with owners and dates.
- Refresh training, starting with the highest-risk roles.
- Agree how the MLRO and compliance functions work together, especially where SMF16 and SMF17 are separate.
- Prepare the ground for the next annual MLRO report so it is evidence-based rather than descriptive.
Interim and fractional MLROs follow the same plan at a different speed. An interim brought in for remediation will often spend the first month entirely on backlog and FCA engagement; a fractional MLRO at a stable small firm may focus on documentation and oversight.
Permanent and Interim MLRO Recruitment
Permanent MLRO Executive Search
Exec Capital’s permanent MLRO search runs on a timetable we agree with you at briefing, taking account of notice periods and the FCA approval step. We access both active and passive candidates — many of the most capable MLROs in the market are not actively looking but are open to the right opportunity. Every MLRO candidate we introduce has been assessed by our team, with specific attention to their FCA fitness and propriety profile, their technical AML knowledge, their track record of regulatory engagement, and their board communication capability. We provide detailed written candidate briefing notes before client interviews, so the firm’s management time is focused on fit and decision-making rather than background verification.
Interim MLRO Recruitment
The most common scenarios requiring an interim MLRO are: sudden departure creating an SMF17 gap; FCA supervisory attention requiring a more experienced individual to lead the AML function; regulatory remediation programmes requiring specialist financial crime leadership; and coverage during parental leave or extended absence. Our interim MLRO network includes individuals with active FCA approval or a history of recent SMF17 designations, with specific experience across financial services sub-sectors — banking, asset management, insurance, payments, consumer credit and e-money. For urgent requirements — particularly where the firm faces an immediate FCA deadline — call 0203 834 9616 directly and we will prioritise your brief, or start with our urgent SMF appointment service. For interim compliance leadership more broadly, see interim CCO.
Fractional and Part-Time MLRO Recruitment
For many smaller authorised firms, start-ups and payment businesses, a full-time MLRO is more than the workload needs. A fractional MLRO gives the firm an experienced, approvable individual for a set number of days a month, with the same personal accountability as a full-time holder. A part-time MLRO works a regular weekly pattern. Both are engaged on a day rate that includes our fee. The key test is time: the FCA will want to see that the MLRO can actually discharge the role in the days available, including SAR decisions that cannot wait for the next scheduled day.
Combined SMF16/SMF17 Appointments
Combined compliance and MLRO appointments are the most frequent request we see from smaller FCA-authorised firms. One person holds SMF16 Compliance Oversight and SMF17 Money Laundering Reporting, usually on a fractional or part-time basis. It works well where the business is not complex and the individual has real depth in both disciplines; it works badly where an AML specialist is stretched over conduct rules they do not know, or the reverse. Our pages on the fractional compliance officer and SMF16 Head of Compliance recruitment, and the guide to SMF16 vs SMF17, explain when a combined role is appropriate.
Deputy MLRO and AML Leadership Recruitment
In larger regulated businesses or those with complex AML risk profiles, a Deputy MLRO provides critical resilience for the SMF17 function — covering the MLRO during absences and managing elements of the AML operational programme. Exec Capital recruits Deputy MLROs, Heads of Financial Crime, AML Directors and senior financial crime professionals across the full spectrum of regulated sectors. These roles do not require FCA SMF approval but demand the same depth of technical AML knowledge and regulatory awareness as the MLRO function itself.
FCA approval and temporary cover for an MLRO
Where SMF17 applies, the timetable for an MLRO hire has two parts: finding the person and getting them approved. The firm submits a Form A, and under section 61 of the Financial Services and Markets Act 2000 the FCA has three months from receipt of a complete application to decide it. The clock stops while the FCA waits for information it has asked for, so a well-prepared application matters. The FCA’s published median for senior manager approvals in 2025/26 was about 25 days (see its authorisations metrics), but individual cases vary.
The SMCR Phase 1 changes that came into force on 24 April 2026 (PS26/6) made temporary cover easier. Under SUP 10C.3A.6R a firm can let someone cover an SMF for an unexpected or temporary absence and has 12 weeks to submit the approval application, with the cover able to continue until the FCA decides it. Criminal record checks for applications are now valid for longer and regulatory reference requests have to be answered faster. The FCA and PRA announcement sets out the package.
In October 2026 the regulators consulted on further changes (FCA CP26/37, PRA CP14/26), including moving a range of SMFs from pre-approval to notification and extending the temporary cover window to 18 weeks. SMF16 and SMF17 are among the functions that would stay pre-approved, so firms should keep planning for a full approval step when they hire an MLRO. The consultations close on 22 January 2027. For more on timing, see how long FCA SMF approval takes.
MLRO Recruitment — Sectors We Cover
| Sector | Key AML / Financial Crime Priorities |
|---|---|
| Retail and commercial banking | High-volume SAR operations, correspondent banking, de-risking strategy, NCA engagement |
| Asset management and wealth management | PEP client management, source of wealth, beneficial ownership, JMLSG Guidance Part II |
| Payments and e-money institutions | Transaction monitoring, FCA PSR/EMR compliance, cross-border transfer risk, mule account detection; MLRO appointed under MLR regulation 21 (outside SMCR) |
| Consumer credit and lending | FCA CONC, affordability-linked AML, digital onboarding KYC, Consumer Duty intersection |
| Insurance | Premium finance, claims fraud, life policy AML risk, reinsurance transactions |
| Fintech and digital assets | Crypto AML (MLR registration), VASP travel rule, blockchain analytics, FCA digital assets regime |
| Legal and accountancy practices | Nominated Officer obligations, SRA/ICAEW supervision, client account CDD, property transaction AML |
| Estate agency and high-value dealers | HMRC MLR supervision, residential property AML, source of funds documentation, luxury goods risk |
Cryptoasset businesses are a growing part of this work. Firms currently registered with the FCA under the MLRs will need full authorisation under the FCA’s new cryptoasset regime, and authorised firms are expected to come within SMCR, so an MLRO who is credible today may need to be approvable as an SMF17 tomorrow. See our digital assets executive recruitment page.
Who we place
Our MLRO clients are typically the CEO, chair, compliance director or investor of a regulated business. The firms range from start-ups preparing their first FCA application to established groups replacing a long-serving MLRO. Typical clients include:
- Small and mid-sized FCA-authorised firms — brokers, wealth managers, asset managers, consumer credit lenders — needing an SMF17, often combined with SMF16.
- Authorised payment institutions and e-money institutions appointing or upgrading their regulation 21 MLRO.
- Banks, building societies and insurers hiring a permanent MLRO, Deputy MLRO or Head of Financial Crime.
- Private equity-backed regulated businesses where the investor wants a stronger financial crime function before or after a deal.
- Cryptoasset and fintech firms preparing for authorisation.
- Professional services firms and other MLR-supervised businesses appointing a Nominated Officer.
The candidates we place are equally varied: career MLROs with several SMF17 approvals behind them, former regulators and skilled persons, heads of financial crime stepping up to their first MLRO role, and experienced compliance officers who can credibly hold SMF16 and SMF17 together. We work across the UK from our offices in London and Cannock, and much MLRO work is hybrid or remote with on-site days agreed with the client.
Looking for an MLRO role? If you are an MLRO, deputy MLRO or financial crime professional, register with us through candidate registration and see current roles on our opportunities page.
Recent MLRO Placements
We do not publish client-identifiable case studies. The mandates we are asked to fill most often are:
- A first dedicated MLRO for a growing payments or e-money firm whose compliance lead has been covering AML alongside everything else and can no longer keep up with transaction monitoring and SAR volumes.
- An interim MLRO during a skilled person review, where the board needs someone with Section 166 experience to lead remediation and handle FCA engagement.
- A combined SMF16/SMF17 holder for a smaller authorised firm, usually on a fractional or part-time basis.
- An MLRO for a cryptoasset or fintech business with blockchain analytics and travel rule experience, ahead of authorisation.
- A Deputy MLRO to give a larger firm resilience and a succession candidate for the SMF17 role.
If your situation matches one of these, we can talk through how similar searches have been approached without naming the firms involved.
How we assess MLRO candidates
An MLRO hire fails in one of three ways: the FCA will not approve the person, the person cannot do the technical job, or the person cannot stand up to the business when it matters. Our assessment covers all three.
- Approvability. We review SMF history, any regulatory or disciplinary findings, financial soundness and what regulatory references are likely to say, so issues surface before Form A rather than after.
- Technical depth. We test knowledge of the MLRs, POCA, JMLSG guidance and sanctions in the context of your products, and ask candidates to walk through real SAR decisions and risk assessments they have owned.
- Regulatory engagement. We look for direct experience of FCA supervisory meetings, thematic reviews, skilled person reviews or remediation.
- Independence and judgement. We look for evidence that the candidate has refused business, escalated concerns or challenged senior colleagues, and how they handled it.
- Capacity. For fractional and part-time roles we check other commitments so the candidate can genuinely cover your firm.
The compliance and risk recruitment practice uses the same approach across SMF16, CRO and audit hires.
Engagement and fees
We agree the fee structure with you at briefing, once we understand the role, the format and the market for it. The main points:
- Permanent MLRO searches are usually run on a retained basis, which gives the search dedicated time and a clear process; contingent terms are sometimes appropriate for less senior AML roles. Our guide to retained vs contingent executive search explains the difference.
- Interim, fractional and part-time MLROs are engaged on a day rate, and that day rate includes our fee. You see one all-in cost, agreed before the assignment starts.
- What is included: taking the brief, market mapping and approaches, candidate assessment and written notes, interview coordination, referencing, offer management and support with the FCA application or notification.
- Conversion: where an interim or fractional MLRO moves into a permanent role, the terms for that are set out at the start.
AML Regulatory and Professional Standards Framework
MLRO appointments operate within one of the most detailed and legally demanding regulatory frameworks in UK financial services. The key standards, legislation and guidance that Exec Capital references in assessing MLRO candidate suitability include:
JMLSG GuidanceJoint Money Laundering Steering Group — industry guidance on the practical implementation of AML obligations in UK financial services
Money Laundering Regulations 2017The primary UK AML regulations, originally implementing the EU’s Fourth Money Laundering Directive — the legal framework within which the MLRO’s obligations and liabilities sit
Proceeds of Crime Act 2002Primary criminal legislation establishing the nominated officer’s personal liability for reporting failures and the legal basis for consent (DAML) SARs
NCA — Suspicious Activity Reports RegimeNational Crime Agency guidance on SAR submission requirements, consent SAR procedures, and the MLRO’s obligations to law enforcement
FATF RecommendationsInternational AML/CFT standards — the global framework that UK legislation and FCA guidance implement and against which UK firms are assessed in FATF mutual evaluations
Discuss Your MLRO Recruitment Requirement
Whether you need a permanent MLRO appointment, an interim to cover an SMF17 gap, a fractional or combined SMF16/SMF17 compliance officer, or a Deputy MLRO for a growing AML function, Exec Capital can help. We agree the timetable with you at briefing.
Frequently Asked Questions — MLRO Recruitment
Does every FCA-regulated firm need an MLRO?
No, not every firm needs an SMF17, but most firms that handle money do need an MLRO in some form. Core and Enhanced SMCR firms that are subject to the FCA’s money laundering systems and controls rules must have an FCA-approved individual holding the SMF17 Money Laundering Reporting Officer function, and there is no minimum size threshold: a small authorised firm in scope needs one as much as a major bank. Most Limited Scope firms do not have an SMF17 requirement. Payment and e-money institutions are outside SMCR but must appoint a nominated officer under regulation 21 of the MLRs. In smaller firms, the SMF17 function is often combined with the SMF16 Compliance Oversight function and held by a single individual. The FCA’s SMCR guidance sets out the requirements for SMF17 designation and the fitness and propriety standards the individual must meet.
What is the difference between an MLRO and a Nominated Officer?
The terms are often used interchangeably but have slightly different technical contexts. MLRO (Money Laundering Reporting Officer) is the title used in FCA-regulated financial services, where in SMCR firms the individual holds the SMF17 function. Nominated Officer is the term used in the Money Laundering Regulations and the Proceeds of Crime Act for the individual who receives internal disclosures across all regulated sectors — including legal firms, accountants, estate agents, and high-value dealers — as well as financial services. The MLRs also require, where appropriate, a board-level officer responsible for compliance with the regulations; in many firms the same person fills both roles. All MLROs are Nominated Officers under the Money Laundering Regulations; not all Nominated Officers are MLROs in the FCA SMCR sense.
How quickly can an interim MLRO be placed to cover an SMF17 gap?
It depends on the firm, the risk profile and candidate availability, so we agree the timetable at briefing rather than promise a fixed turnaround. Interim MLROs are often available sooner than permanent candidates because they are not working out long notice periods. On the regulatory side, SUP 10C.3A.6R lets a firm put temporary cover in place for an unexpected absence and gives it 12 weeks to submit an application for the replacement; the October 2026 consultations propose extending this to 18 weeks. For urgent MLRO coverage requirements, call 0203 834 9616 directly and we will treat your brief as a priority.
What qualifications should an MLRO have?
The most widely recognised professional qualifications for MLROs in UK financial services are the International Compliance Association (ICA) International Diploma in Anti Money Laundering, the ACAMS CAMS certification, and the CISI Certificate in AML. Many experienced MLROs hold a combination of these alongside broader compliance qualifications such as the ICA Diploma in Compliance or CISI Certificate in Compliance. At the most senior level, a strong track record of practical AML programme management, FCA regulatory engagement and SAR decision-making carries more weight than any specific certification. The FCA assesses fitness and propriety holistically — qualifications are one element alongside experience, track record and personal integrity.
Can the MLRO be the same person as the CCO?
Yes — in many regulated firms, particularly smaller ones, the SMF16 (Compliance Oversight) and SMF17 (MLRO) functions are held by a single individual. The FCA permits this dual-hat arrangement and it is common practice across the market. The key requirement is that the individual has sufficient capacity to fulfil both functions adequately — if the combined compliance and AML workload exceeds what one person can manage effectively, the FCA expects the firm to make appropriate resourcing decisions. In larger or more complex regulated businesses, separate SMF16 and SMF17 holders is the norm. Exec Capital recruits for both combined and separate role structures. See our CCO recruitment page for the broader compliance leadership context.
How does the FCA assess an MLRO candidate’s fitness and propriety?
The FCA’s fitness and propriety assessment for SMF17 approval evaluates three core dimensions. Honesty, integrity and reputation — the individual must have a clean regulatory record, no relevant criminal history, and a professional reputation that is consistent with FCA expectations. Competence and capability — the individual must have the knowledge, skills and experience to perform the MLRO function effectively for the firm’s specific business model and risk profile. Financial soundness — the individual must not have unmanageable financial difficulties that could create vulnerability to corruption or undue influence. The FCA can reject an SMF17 application and the firm must not appoint the individual to the function until approval is granted, other than under the temporary cover rule. Exec Capital assesses all these dimensions as part of our candidate evaluation before introducing MLRO candidates.
Do payment and e-money institutions need an SMF17?
No. Authorised payment institutions and e-money institutions regulated only under the Payment Services Regulations 2017 or the Electronic Money Regulations 2011 are outside SMCR, so there is no SMF17. They must still appoint a nominated officer and, where appropriate, a board-level officer responsible for MLR compliance under regulation 21 of the MLRs, and the FCA assesses the people managing the firm at authorisation. If the firm later takes on a Part 4A permission it moves into SMCR.
Can we hire a fractional or part-time MLRO?
Yes. Many smaller authorised firms and payment businesses use a fractional MLRO for a set number of days a month, or a part-time MLRO on a weekly pattern. The individual carries the same accountability as a full-time MLRO, so the arrangement has to give them enough time, access and authority, including cover for SAR decisions between scheduled days.
How long does FCA approval of an MLRO take?
Under section 61 of FSMA the FCA must decide a complete application within three months, with the clock stopping while it waits for information it has requested. The FCA’s published median for senior manager approvals in 2025/26 was about 25 days. A clean, complete Form A with criminal record checks and regulatory references in hand is the best way to keep within that range.
How are MLRO search fees structured?
We agree the fee structure at briefing. Permanent MLRO searches are usually retained; interim, fractional and part-time MLROs are engaged on a day rate that includes our fee. We do not publish standard fees because the right structure depends on the role, the format and the urgency.
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Sources and References
- FCA — Financial Crime and Anti Money Laundering Guidance
- FCA — Senior Managers and Certification Regime (SMCR)
- FCA — FCA and PRA confirm changes to streamline senior manager accountability (April 2026)
- Bank of England — Regulators unveil plans to simplify SMCR (October 2026)
- Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017
- Money Laundering Regulations 2017 — regulation 21 (internal controls, nominated officer)
- Proceeds of Crime Act 2002 — UK Legislation
- National Crime Agency — Suspicious Activity Reports Guidance
- Joint Money Laundering Steering Group (JMLSG) — AML Guidance
- FATF — International AML/CFT Recommendations and Standards
- OFSI — UK Financial Sanctions Guidance
- FCA — Section 166 Skilled Persons Reviews
- International Compliance Association (ICA) — AML and Compliance Qualifications
- Institute of Chartered Accountants in England and Wales (ICAEW)
- Adrian Lawrence FCA — ICAEW Registered Practice
- ResearchGate — The Evolution of Fractional C-Suite Leadership in Modern UK Businesses (Adrian Lawrence FCA, 2026)
- ResearchGate — The Strategic Role of Fractional and Interim Executives (Adrian Lawrence FCA, 2026)
Need an MLRO you can rely on?
Tell us whether you need a permanent SMF17, an interim to cover a gap, a fractional MLRO or a combined SMF16/SMF17 compliance officer, and we will agree the brief and timetable with you. You can also contact us directly.
Related Compliance and MLRO Search Services
Exec Capital places MLROs, compliance officers and financial crime leaders on permanent, interim, fractional and part-time terms across the UK. Every search is run by our specialist team, with Adrian Lawrence FCA overseeing each mandate.
PRACTICE AREA
Fractional & Part-Time MLRO
Experienced, approvable MLROs for a set number of days a month or a regular weekly pattern.
PRACTICE AREA
Combined SMF16/SMF17
One compliance officer holding compliance oversight and money laundering reporting for a smaller firm.
→ Fractional Compliance Officer
PRACTICE AREA
Interim & Urgent Cover
Cover for a departed MLRO or compliance officer while the 12-week temporary cover window runs.
PRACTICE AREA
Compliance Leadership
Chief compliance officers and compliance and risk leaders for authorised firms and fintechs.
Every search is run by our specialist team, with Adrian Lawrence FCA overseeing each mandate.
About the author
Adrian Lawrence FCA is the founder of Exec Capital. He is a Chartered Accountant holding an ICAEW practising certificate in his own name, with more than 25 years’ experience operating at C-suite level. His background spans private equity-backed businesses, owner-managed companies and listed environments, giving Exec Capital a practitioner’s understanding of what senior leadership hires actually require. View Adrian’s ICAEW profile.