Part-Time MLRO

UK Part-Time MLRO Recruitment — SMF17 Money Laundering Reporting Officer Search at Smaller FCA-Authorised Firms Operating Part-Time SMF17 Arrangements

Exec Capital provides retained Part-Time MLRO search across the UK FCA-authorised firm community — covering Money Laundering Reporting Officer (SMF17) appointments at smaller UK FCA-authorised firms operating part-time SMF17 arrangements rather than full-time MLRO appointments. The Part-Time MLRO market serves a specific UK FCA-authorised firm community where the firm’s regulatory MLRO scope is genuinely part-time in volume — typically smaller payments firms, smaller Electronic Money Institutions (EMIs), smaller wealth management firms, smaller fund management firms, smaller consumer credit firms, smaller mortgage broker firms, and the wider UK FCA-authorised firm community where senior full-time MLRO economics are not warranted by the firm’s scale or risk profile. The Part-Time MLRO arrangement is structurally distinct from full-time MLRO senior search at major UK firms — covered by sister site FD Capital MLRO recruitment alongside the wider FD Capital senior MLRO and AML knowledge authority — and from full-time permanent MLRO appointments at scale UK firms covered through our broader MLRO recruitment service.

UK Part-Time MLRO arrangements have grown materially since 2018 alongside the maturation of the UK fintech, payments, e-money, and smaller-firm FCA-authorised community. The principal drivers include the material growth in UK FCA-authorised payments firms and EMIs (firms typically smaller than full-time MLRO economics warrant), the regulatory framework permitting Part-Time MLRO arrangements where the firm’s MLRO scope is genuinely accommodated within a part-time basis, the senior independence required of MLRO roles which Part-Time MLRO arrangements can support effectively where the candidate is appropriately credentialled, and the wider UK senior compliance professional community operating Part-Time MLRO portfolios across multiple smaller firms. It is a concentrated, well-networked community, which is why a targeted search usually outperforms an advert.

How it works: hiring a part-time MLRO with Exec Capital

Most firms that contact us about a part-time MLRO have one of three triggers: an authorisation application that needs a named MLRO, an existing MLRO who is leaving, or a supervisory letter or audit finding that shows the current arrangement is not enough. The process below is the same in each case; what changes is the pace. We agree the timetable with you at briefing, around your FCA deadlines rather than ours.

If you need someone named quickly because an MLRO has gone or an application is stuck, tell us on the first call. Our urgent SMF appointment service is built for that situation, and the brief can be taken the same day.

The Part-Time MLRO Role and the FCA SMF17 Framework

The Money Laundering Reporting Officer role at UK SMCR firms is designated as SMF17 under the FCA Senior Managers and Certification Regime. SMF17 designation applies regardless of whether the MLRO arrangement is full-time, part-time, or fractional — the senior regulatory accountability framework is consistent across engagement structures. The Part-Time MLRO arrangement adapts the engagement model rather than the senior regulatory accountability framework.

SMF17 Senior Manager Function designation — SMCR firms (Core and Enhanced) that are subject to the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017) appoint their MLRO as SMF17. SMF17 designation requires FCA pre-approval through a Form A submission, fit-and-proper assessment by the firm and the FCA, regulatory references from previous regulated employers, and ongoing personal regulatory accountability under the SMCR conduct rules. Payment institutions and e-money institutions are outside the SMCR: they appoint an MLRO (the nominated officer) under regulation 21 of the MLRs, and the FCA assesses the people responsible for managing them as part of authorisation, but not as Senior Managers. Limited scope SMCR firms should check which functions apply to them before assuming SMF17 is needed.

SMF17 remains a pre-approved role — in October 2026 the FCA (CP26/37) and the PRA (CP14/26) consulted on moving several Senior Manager Functions from pre-approval to notification. SMF16 Compliance Oversight and SMF17 Money Laundering Reporting stay on the pre-approval list under those proposals, so a part-time MLRO at an SMCR firm still needs FCA approval before taking up the function, however few days a week they work.

Statement of Responsibilities (SoR) — Part-Time MLRO appointments at SMCR firms require a Statement of Responsibilities documenting the SMF17 holder’s specific senior regulatory accountability scope. Where the engagement structure is genuinely part-time, the SoR documents the part-time nature alongside the senior regulatory accountability scope. SoR documentation operates as the principal regulatory record of the SMF holder’s senior accountability framework.

Fit and Proper assessment — Part-Time MLRO candidates undergo the same FCA fit-and-proper assessment as full-time MLRO candidates. Fit-and-proper assessment covers the candidate’s honesty, integrity and reputation, competence and capability for the senior role, financial soundness, and the wider FCA fit-and-proper criteria. The senior regulatory standards that apply to MLRO fit-and-proper are not reduced by part-time engagement structure.

Conduct rules application — Part-Time MLRO holders operate under the FCA Senior Manager Conduct Rules (SC1-SC4) and the wider Conduct Rules (COCON 2) with personal regulatory accountability for ongoing conduct standards. Senior Manager Conduct Rule SC1 (take reasonable steps to ensure that the business of the firm for which you are responsible is controlled effectively) carries particular weight for a part-time SMF17 holder, because the firm and the FCA will ask whether the days committed were enough to control the AML area properly.

Regulatory references — Part-Time MLRO appointments require regulatory references from previous regulated employers where the candidate has held SMF or Certified Function status. Regulatory reference processing affects the appointment timeline, with associated implications for offer construction at Part-Time MLRO level.

The MLRO’s principal substantive responsibilities — across UK FCA-authorised firms include receiving internal Suspicious Activity Reports (SARs) from firm employees, evaluating internal SARs and submitting external SARs to the National Crime Agency (NCA) where appropriate, designing and maintaining the firm’s anti-money laundering (AML) policy, designing and maintaining customer due diligence (CDD) frameworks aligned with the firm’s risk-based approach, managing the firm’s sanctions compliance framework aligned with the Office of Financial Sanctions Implementation (OFSI) regulatory framework, providing senior commercial dimensions of AML and financial crime training across the firm, engaging with the FCA and the NCA on AML and financial crime matters, and the wider senior dimensions specific to MLRO regulatory accountability. For a fuller breakdown of duties, see our MLRO job description.

Part-time MLRO: employed part-time vs contractor vs combined SMF16/17

“Part-time” covers three quite different arrangements. The right one depends on how much AML work your firm actually generates, whether you also need a compliance oversight holder, and how much continuity the FCA will expect to see. All three carry the same regulatory accountability; what changes is the contract, the cost structure and how embedded the person is.

A combined SMF16/17 part-time holder is now one of the most common requests we receive from smaller FCA-authorised firms. It works well when the person has genuine depth in both compliance monitoring and financial crime, and when the board understands that combining the roles concentrates judgement in one person. Where the firm needs a more senior compliance lead who also sits with the board, a fractional Chief Compliance Officer may be the better fit, with AML handled alongside.

Common UK Part-Time MLRO Scenarios

UK Part-Time MLRO arrangements operate across specific FCA-authorised firm scenarios where part-time SMF17 arrangements are commercially appropriate. Understanding which scenario applies shapes the senior search engagement design.

Smaller UK payments firms and EMIs

UK payments firms and Electronic Money Institutions (EMIs) authorised under the Payment Services Regulations 2017 and the Electronic Money Regulations 2011 at smaller scale typically operate Part-Time MLRO arrangements during the early growth phase when senior MLRO regulatory scope is genuinely accommodated within part-time engagement. These firms are outside the SMCR, so the MLRO is appointed under the MLRs rather than approved as SMF17, but the FCA still looks closely at the MLRO’s experience and time commitment at authorisation and in supervision. Smaller UK payments firms and smaller EMIs frequently transition to full-time MLRO as they scale — typically on material customer or transaction growth, new higher-risk products or corridors, or specific FCA expectations triggered by enforcement or thematic work. Our guide to senior hiring at payment institutions covers the wider leadership picture.

Smaller UK wealth management firms

UK wealth management firms operating with smaller AUM frequently appoint Part-Time MLRO arrangements where the senior regulatory MLRO scope can be genuinely accommodated in part-time engagement. Smaller UK wealth management firm Part-Time MLRO scope typically includes senior CDD oversight at client onboarding, sanctions screening, ongoing customer monitoring, SARs reporting, and the wider senior MLRO accountability dimensions specific to wealth management firm AML requirements.

Smaller UK fund management firms

UK fund management firms operating at smaller scale (typically smaller fund AUM, smaller management firm operations) frequently appoint Part-Time MLRO arrangements where the senior MLRO scope is genuinely accommodated in part-time engagement. Smaller UK fund management firm Part-Time MLRO scope typically includes senior accountability for AIFMD-related AML requirements where the firm operates AIFs, senior CDD oversight at LP onboarding, sanctions screening across portfolio companies and counterparties, and the wider senior MLRO dimensions specific to fund management AML requirements.

Smaller UK consumer credit and mortgage broker firms

UK consumer credit firms and mortgage broker firms authorised by the FCA operating at smaller scale frequently appoint Part-Time MLRO arrangements where senior MLRO scope is genuinely accommodated in part-time engagement. Smaller UK consumer credit and mortgage broker firm Part-Time MLRO scope typically includes senior CDD oversight at customer onboarding, sanctions screening, ongoing monitoring, SARs reporting, and the wider senior MLRO accountability dimensions specific to consumer credit and mortgage broker AML requirements.

Newly-authorised UK FCA-authorised firms during early operations

Newly-authorised UK FCA-authorised firms frequently appoint Part-Time MLRO arrangements during early operations before the firm reaches scale where full-time MLRO economics are warranted. Newly-authorised firm Part-Time MLRO scope typically includes designing the firm’s initial AML framework, establishing CDD processes, establishing sanctions screening processes, registering with the NCA’s SAR Online system, and the wider senior MLRO dimensions specific to firm-establishment activity.

Firms applying for authorisation

An authorisation application is a common trigger. The FCA expects to see who will hold the MLRO role, how much time they will give it and how the AML framework will work from day one. A part-time MLRO who has taken firms through authorisation before can draft or review the business-wide risk assessment and policies that go into the application. Our guide to building your SMF team from scratch explains how the MLRO fits alongside the other roles.

Gambling operators

Gambling operators are not FCA-regulated, but they carry real AML obligations, and since 29 November 2024 the Gambling Commission has required the person responsible for AML and counter-terrorist financing (the nominated officer) to hold a personal management licence, with an exception for small-scale operators. See the Commission’s notice on the new personal management licence requirements. Smaller remote operators and new licence applicants often fill that role part-time, and the licence requirement narrows the pool to people prepared to hold it personally.

Cryptoasset firms moving to FCA authorisation

Cryptoasset businesses currently registered with the FCA under the MLRs are moving to full FSMA authorisation. The new regime starts on 25 October 2027, with the application window running from 30 September 2026 to 28 February 2027, and the FCA’s final rules apply its Handbook to authorised cryptoasset firms, including the senior managers regime (see the FCA’s overview of the cryptoasset policy statements). A crypto firm with a part-time MLRO today needs to decide whether that person can be put forward for SMF17 approval, and whether the time commitment will still be credible under the new regime. Our crypto firm SMCR guide sets out the wider board requirements.

When to hire a part-time MLRO, and when another format fits better

Part-time is the right answer when the AML workload is real but steady and modest: a contained customer base, a limited number of products, few higher-risk jurisdictions and a manageable flow of internal suspicion reports. It is the wrong answer if the volume of alerts, SARs or onboarding exceptions already fills a working week, or if the FCA has told you it expects more senior time on financial crime. The table sets out the main options.

Firms often move between these formats as they grow: a newly authorised firm may start with a fractional MLRO, move to a part-time MLRO as volumes build, and then hire a full-time MLRO. Our guide to choosing a permanent, interim or fractional compliance hire sets out the trade-offs in more detail.

Other ways to hire an MLRO. If you want an ongoing outsourced arrangement across a few days a month, see our fractional MLRO service. If you need a full-time permanent appointment, see MLRO recruitment. For a compliance lead who can also cover AML, see fractional compliance officer and fractional CCO. If the role has fallen vacant and you need cover now, see urgent SMF appointment.

What makes part-time MLRO search different

Part-time MLRO search has three specific dimensions that distinguish it from broader senior MLRO recruitment at major UK firms. First, the role itself operates under the same regulatory framework as a full-time MLRO — at SMCR firms that means SMF17 designation with personal regulatory accountability, fit-and-proper assessment, regulatory references from previous regulated employers, and the wider personal regulatory accountability framework that applies to MLRO appointments regardless of part-time or full-time engagement structure. The smaller scale of the firm does not reduce the accountability that applies — Part-Time MLRO candidates need to demonstrate the same regulatory capability and career background as full-time MLRO candidates.

Second, the candidate pool dynamics for UK Part-Time MLRO appointments are distinct from the full-time MLRO market. Strong UK Part-Time MLRO candidates often run portfolios across several smaller regulated firms at once, depending on the demands of each. The Part-Time MLRO community is concentrated and well known across the UK compliance profession, so capacity, conflicts and reputation all need checking.

Third, the cross-portfolio architecture matters. Full-time MLRO appointments at major UK FCA-authorised firms — major payments firms, major EMIs, scale wealth managers, major fund managers, major banks, major insurers — are senior appointments where MLRO careers progress to broader compliance leadership, and where the dynamics are best handled through FD Capital, our sister-site MLRO and compliance specialist. At Exec Capital we focus Part-Time MLRO search on smaller regulated firms operating part-time arrangements — typically smaller payments firms, smaller EMIs, smaller wealth managers, smaller fund managers, smaller consumer credit firms, and the wider smaller-firm community where part-time arrangements are commercially appropriate. Where the search evolves toward a full-time MLRO appointment, we work with FD Capital across the group.

UK AML Regulatory Framework — Substantive Background

UK MLRO senior regulatory scope operates within a specific framework of UK legislation, regulation, and senior compliance dimensions. Understanding the regulatory framework is essential for senior search engagement design.

Money Laundering Regulations 2017 (MLR 2017) — the principal UK statutory framework for AML compliance at UK firms covered by the Regulations including FCA-authorised firms across the principal authorisation categories. MLR 2017 establishes the senior obligations on relevant persons including risk-based approach implementation, customer due diligence requirements, enhanced due diligence triggers (Politically Exposed Persons, high-risk third countries), simplified due diligence permissions, ongoing monitoring obligations, and the wider AML compliance framework. MLR 2017 has been amended several times since 2019, most recently by the Money Laundering and Terrorist Financing (Amendment) Regulations 2026, most of which came into force on 30 June 2026. Those amendments update areas such as due diligence and cryptoasset controls, but they do not change the provisions on appointing an MLRO or nominated officer, so a part-time arrangement that was compliant before remains a valid structure.

Proceeds of Crime Act 2002 (POCA 2002) — the principal UK statutory framework for proceeds-of-crime offences including the principal money laundering offences (sections 327-329), the failure to disclose offence (section 330) which applies to MLROs and other relevant persons, the tipping-off offence (section 333A), and the wider POCA framework. MLRO senior regulatory accountability operates within the POCA section 330 framework with associated personal liability dimensions. Section 331 creates a parallel failure-to-disclose offence aimed specifically at nominated officers in the regulated sector.

Suspicious Activity Reports (SARs) framework — the principal UK SARs framework operates through the National Crime Agency’s SAR Online portal with MLRO senior accountability for SAR submission decisions. SARs framework dimensions include Defence Against Money Laundering (DAML) SARs, Defence Against Terrorist Financing (DATF) SARs, ongoing review of consent decisions, and the wider senior MLRO accountability dimensions specific to SARs management. Under section 335 of POCA, the NCA has a notice period of seven working days to respond to a DAML request, during which the transaction normally has to wait. This is why a part-time MLRO arrangement must include clear availability and a named deputy: a DAML decision cannot sit until the MLRO’s next scheduled day.

Office of Financial Sanctions Implementation (OFSI) framework — UK financial sanctions compliance operates through the OFSI regulatory framework with senior MLRO accountability for sanctions screening, asset freezing implementation, sanctions reporting, and the wider senior compliance dimensions. OFSI’s senior commercial dimensions have grown materially since 2022 alongside the substantive expansion of UK financial sanctions following the Russia sanctions framework.

FCA AML supervision and enforcement — the FCA’s AML supervision framework includes thematic work, supervisory engagement at firm level, enforcement action where AML failings are identified, and the wider senior dimensions of FCA AML supervisory engagement. The FCA’s Financial Crime Guide (FCG) operates as the principal FCA-published AML guidance for FCA-authorised firms.

Joint Money Laundering Steering Group (JMLSG) Guidance — the JMLSG Guidance operates as the principal industry-published AML guidance for UK FCA-authorised firms across the principal sectors. JMLSG Guidance is HM Treasury-approved and provides the senior commercial dimensions of how UK FCA-authorised firms should implement MLR 2017 obligations across risk-based approach, customer due diligence, enhanced due diligence, ongoing monitoring, and the wider AML framework.

How many days a week does a part-time MLRO need?

There is no regulatory formula. The FCA expects the MLRO to have enough time, authority and resources to do the job properly, and it judges that against the firm’s own risk profile. In practice, the days needed depend on a handful of factors we work through at briefing:

• Customer numbers and onboarding volume. Each new customer needs due diligence, and exceptions need MLRO sign-off. A firm onboarding steadily every week needs more time than one with a stable book.
• Product and channel risk. Cross-border payments, cash-intensive customers, high-value transactions, non-face-to-face onboarding and higher-risk jurisdictions all push the workload up.
• Alert and internal report volume. Transaction monitoring alerts, sanctions hits and internal suspicion reports all need review. If they are already backing up, part-time may be too little.
• State of the framework. A firm with a current risk assessment, tested controls and trained staff needs less MLRO time than one rebuilding after an audit finding.
• Team support. A part-time MLRO with an analyst or a deputy can cover more than one who does every task personally.
• Supervisory attention. Open FCA correspondence, a skilled person review or a remediation programme usually means more days, at least for a period.

As a rule of thumb, firms tend to start with a fixed number of days and a clear arrangement for urgent matters between those days. We would rather tell you at briefing that the role is bigger than part-time than place someone into an arrangement the FCA will later challenge.

What a part-time MLRO typically delivers in the first 90 days

A good part-time MLRO uses the first three months to understand the firm’s real exposure, fix anything urgent and set up reporting the board can rely on. A typical first 90 days looks like this:

Days 1 to 30: understand and stabilise

• Review the business-wide risk assessment, AML policies, controls and procedures against MLR 2017 and current JMLSG guidance.
• Check the SAR and DAML log, any open internal reports, and any decisions that are waiting.
• Sample customer files to test due diligence and enhanced due diligence quality.
• Confirm sanctions screening coverage and settings, and how hits are escalated.
• Agree a deputy and an out-of-hours escalation route so urgent matters are not left waiting.

Days 31 to 60: fix and document

• Prioritise and start remediating gaps, with a written plan the board can follow.
• Update policies where they no longer match how the firm actually operates.
• Run or refresh AML training for staff, with records kept.
• Set up regular management information on alerts, internal reports, SARs, high-risk customers and screening results.

Days 61 to 90: report and embed

• Present a first report to the board or senior management on the state of the AML framework and the remediation plan.
• Agree the MLRO annual report timetable and any regulatory returns that apply to the firm.
• Review whether the agreed days are enough, and say so if they are not.
• Plan independent testing of the AML framework where it is appropriate for the firm’s size and nature.

Compensation Calibration at UK Part-Time MLRO Level

UK Part-Time MLRO compensation operates with specific dynamics distinct from full-time MLRO senior compensation. Understanding the compensation framework is essential for senior search engagement design.

Day rate engagements — UK Part-Time MLRO senior candidates frequently operate under day-rate engagement structures across multiple smaller FCA-authorised firms. Day rates vary with the sector, the firm’s risk profile, the candidate’s SMF history and whether they also cover SMF16; candidates with extensive MLRO career background, multi-firm portfolio experience and a track record with the FCA sit at the upper end of the market. We give you a current view at briefing rather than quoting a range here that may not fit your firm.

Monthly retainer engagements — selected UK Part-Time MLRO arrangements operate under monthly retainer structures rather than day-rate engagements, with the level depending on the firm’s scale, regulatory complexity, and MLRO scope. Retainer structures suit firms preferring predictable monthly costs, provided the agreement is clear about what happens when the workload exceeds the agreed time.

FTE-equivalent compensation — UK Part-Time MLRO candidates operating across multi-firm portfolios frequently calculate FTE-equivalent compensation across their portfolio, comparing their total earnings against a full-time MLRO salary. Senior Part-Time MLRO candidates with extensive portfolio operations and senior career background frequently price above the full-time equivalent, reflecting the flexibility and immediate experience they bring. Our SMF salary guide gives sourced context on senior compliance pay.

Engagement structure considerations — UK Part-Time MLRO engagement structures commonly include consultancy engagement (Part-Time MLRO operating as self-employed contractor through personal services company or self-employment), employment engagement (Part-Time MLRO operating as part-time employee of the firm with associated employment law dimensions), and outsourced compliance firm engagement (Part-Time MLRO provided through a compliance consultancy firm with senior commercial dimensions specific to the consultancy structure). Each engagement structure has senior dimensions specific to FCA SMF17 designation framework — including the firm’s accountability for ensuring senior fit-and-proper assessment regardless of engagement structure.

Engagement and fees

We keep the commercial side simple and agree it before any search starts. The fee structure is agreed at briefing and depends on the format of the hire:

• Retained search for employed part-time MLRO appointments, where we commit dedicated search time to a defined brief. Our guide to retained vs contingent executive search explains the difference.
• Contingent arrangements can suit some simpler briefs; we will say at briefing which approach fits.
• Day-rate basis for contractor, interim and fractional MLROs. The day rate you pay includes our fee, so there is one figure to budget for.
• What is included: the brief, market mapping, approaches, interviews, regulatory due diligence (SMF history, references and conflicts), shortlist notes, offer support, help preparing for the FCA application where SMF17 applies, and contact through onboarding.

If a firm’s needs change during the search, for example from part-time to full-time, or from a single MLRO to a combined SMF16/17, we revisit the brief with you rather than starting again.

The UK Part-Time MLRO Candidate Pool

UK Part-Time MLRO senior candidates draw from specific career communities. Understanding the candidate pool dynamics is essential for senior search engagement design.

Senior career portfolio Part-Time MLROs — the principal UK Part-Time MLRO candidate pool consists of senior compliance professionals operating Part-Time MLRO portfolios across multiple smaller UK FCA-authorised firms. Senior portfolio Part-Time MLROs typically hold extensive senior MLRO career background, established relationships across the smaller FCA-authorised firm community, and the senior career trajectory specific to Part-Time MLRO senior delivery.

Senior compliance candidates transitioning from full-time roles — senior compliance professionals transitioning from full-time senior compliance roles at major UK FCA-authorised firms (frequently following firm restructuring, senior role transitions, or career-stage transitions toward portfolio working). This candidate pool brings senior career background at major firm scale and frequently operates Part-Time MLRO portfolios alongside selected senior advisory engagements.

Compliance consultancy senior practitioners — senior compliance professionals at UK compliance consultancy firms providing outsourced Part-Time MLRO services to smaller UK FCA-authorised firms. Compliance consultancy Part-Time MLRO arrangements operate through the consultancy firm with associated senior commercial dimensions specific to the consultancy structure.

Senior career-stage compliance professionals — senior career-stage UK compliance professionals operating in the later stages of their senior careers and choosing Part-Time MLRO portfolios as the principal engagement structure. This candidate pool frequently brings extensive senior career background, established UK FCA-authorised firm relationships, and the senior commercial dimensions specific to senior career-stage Part-Time MLRO delivery.

What we test for in every candidate. Whatever the source, we look for hands-on SAR and DAML decision-making, sector-relevant due diligence experience, a clean regulatory history, sensible capacity across other commitments, and the confidence to challenge a CEO or founder when a customer or transaction should not go ahead.

How Exec Capital Approaches Part-Time MLRO Search

UK Part-Time MLRO search at Exec Capital follows a retained methodology calibrated to the specific dynamics of Part-Time MLRO senior recruitment, including the cross-portfolio handoff dimensions where the senior search engagement transitions toward full-time MLRO appointment. Every search is run by our specialist team, with Adrian Lawrence FCA overseeing each mandate.

Brief development — initial work focuses on defining the firm’s specific Part-Time MLRO requirement (firm sector and regulatory authorisation type, firm scale and senior MLRO scope, the realistic engagement structure including day-rate vs retainer preferences, the realistic compensation envelope, and the candidate-fit dimensions specific to the firm’s senior team and senior compliance framework). Where the brief evolves toward full-time MLRO senior search, we work with FD Capital cross-portfolio.

Senior candidate identification — UK Part-Time MLRO candidate identification operates across senior career portfolio Part-Time MLROs, senior compliance candidates transitioning from full-time roles, compliance consultancy senior practitioners, and senior career-stage compliance professionals. Coverage is structured by sector specialisation (payments, EMIs, wealth management, fund management, consumer credit, mortgage broker) and senior career trajectory.

Senior FCA regulatory due diligence — comprehensive evaluation of the candidate’s prior SMF17 history where applicable, regulatory references from previous regulated employers, fit-and-proper assessment alignment, and any regulatory or conduct issues that could affect SMF17 pre-approval at the receiving firm. Where the candidate operates Part-Time MLRO portfolios across multiple firms, senior assessment includes capacity dimensions and conflict-of-interest considerations.

Engagement structure design — senior search engagement at Part-Time MLRO level frequently includes engagement structure design alongside senior candidate identification — including day-rate vs retainer structures, consultancy vs employment engagement structures, conflict-of-interest framework where the candidate operates multi-firm portfolios, and the wider senior commercial dimensions of Part-Time MLRO engagement.

Interview process — typically 3-5 rounds at Part-Time MLRO level including senior CEO or senior compliance leader interviews, senior board engagement (where applicable at firms operating senior compliance committee structures), senior firm-internal stakeholder engagement across compliance, risk, finance, and operational functions, and the wider senior dimensions specific to Part-Time MLRO senior assessment.

Cross-portfolio handoff to FD Capital — where the senior search engagement evolves toward senior full-time MLRO appointment at scale, we work with FD Capital cross-portfolio. FD Capital is our sister site senior MLRO and senior compliance specialist with concentrated MLRO and AML knowledge depth across the UK senior MLRO professional community.

SMF17 approval, timing and temporary cover

For SMCR firms, the FCA approval step often decides when a part-time MLRO can actually start, so it is worth planning from the first conversation.

• Statutory deadline. Under section 61 of the Financial Services and Markets Act 2000, the regulator must decide a complete application within three months. The clock stops while the FCA waits for information it has asked for, so a complete, well-prepared application matters.
• Typical timing. The FCA’s published median for Senior Manager approvals in 2025/26 was around 25 days. Individual cases vary, and an incomplete application or an unusual candidate history can take much longer. Our guide on how long FCA SMF approval takes sets out the detail.
• Temporary cover. If an MLRO leaves unexpectedly, SUP 10C.3A.6R (as amended by PS26/6 from 24 April 2026) allows someone to cover the function temporarily, provided the firm submits an application for a permanent holder within 12 weeks; cover can continue until that application is decided. The FCA’s CP26/37 proposes extending the 12 weeks to 18, but that is a consultation, not a rule. Our guide to interim SMF16 and SMF17 cover explains how firms use this period.
• Payment and e-money firms. These firms are outside the SMCR, so the SMF approval and 12-week rules do not apply. They still need to tell the FCA about changes to the people responsible for management and AML, and the incoming MLRO’s experience will be scrutinised.

We help prepare the candidate’s information for the application and check references and regulatory history early, so the FCA has fewer reasons to come back with questions.

Who we place part-time MLROs for

Our part-time MLRO clients are usually owner-managed, founder-led or investor-backed firms where the CEO or a small board needs a credible AML lead without the cost of a full-time hire. Typical clients include:

• Payment institutions, e-money institutions and agents of larger payment firms, including firms preparing for authorisation.
• Wealth managers, financial advisers and discretionary investment managers; see our wealth management recruitment page for the wider leadership roles.
• Smaller fund managers, AIFMs and family-office-linked investment businesses.
• Consumer credit lenders, credit brokers and mortgage intermediaries.
• Fintech firms adding regulated permissions; see fintech recruitment.
• Cryptoasset businesses preparing for FSMA authorisation.
• Gambling operators that need a licensed nominated officer.
• Investment firms and brokers with a modest client base and a clear AML risk profile.

Many of these firms also need a compliance oversight holder. We can search for both roles at the same time, or for one person who can credibly hold both.

Signs your part-time MLRO arrangement needs reviewing

Part-time arrangements work well until the firm outgrows them. These are the signals we see most often when firms come back to us to increase days, add a deputy or move to a full-time hire:

• Internal suspicion reports or monitoring alerts are waiting longer than the firm’s own procedures allow.
• DAML decisions are being made in a rush because the MLRO was not available when the transaction arose.
• The board report is late, thin or missing management information.
• Customer due diligence files keep failing internal or external sampling.
• The firm has launched new products, corridors or customer types without the MLRO’s risk assessment being updated.
• The FCA or an auditor has questioned whether the MLRO has enough time or resource.

If any of these apply, it is worth a conversation before the regulator raises it. We can usually tell quickly whether the answer is more days, a deputy, a combined compliance lead or a full-time MLRO. You can contact us or call 0203 834 9616.

Looking for part-time MLRO roles?

This page is written for firms hiring. If you are an MLRO or AML specialist looking for part-time, fractional or interim roles, please register with us and keep an eye on our current opportunities. We keep a confidential record of availability, sectors and SMF history so we can contact you when a suitable brief comes in.

Frequently asked questions

What is a part-time MLRO?

A part-time MLRO is a Money Laundering Reporting Officer who holds the role for a set number of days a week or month rather than full-time. They carry the same legal and regulatory responsibilities as a full-time MLRO, including SAR decisions and oversight of the firm’s AML framework.

Can a part-time money laundering reporting officer hold SMF17?

Yes. SMF17 does not depend on working hours. A part-time MLRO at an SMCR firm needs FCA approval before taking up the function, and the firm must be able to show that the time committed is enough for its risk profile.

Is SMF17 changing under the FCA’s 2026 SMCR proposals?

Under CP26/37 and the PRA’s CP14/26, several functions are proposed to move from pre-approval to notification, but SMF16 and SMF17 remain pre-approved. A part-time MLRO at an SMCR firm will still need approval before starting.

Do payment and e-money institutions need an SMF17?

No. Payment and e-money institutions are outside the SMCR. They appoint an MLRO under regulation 21 of the Money Laundering Regulations, and the FCA assesses their key people at authorisation and in supervision, but not as Senior Managers.

How many days a week does a part-time MLRO work?

It depends on the firm’s customer numbers, product risk, alert volumes and the state of its AML framework. There is no fixed regulatory minimum; we agree a realistic commitment at briefing and build in cover for urgent decisions between scheduled days.

Can one person be part-time SMF16 and SMF17?

Yes, at many smaller firms one person holds both Compliance Oversight and MLRO. Both functions need approval and the time commitment has to cover both. See our guide to combining SMF roles.

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

A part-time MLRO usually works fixed days each week, often as an employee or a dedicated contractor. A fractional or outsourced MLRO typically gives a few days a month on an ongoing basis and may serve several firms. Our fractional MLRO page covers that model.

How long does it take to appoint a part-time MLRO?

It depends on the search and on FCA approval where SMF17 applies. The FCA’s published median for Senior Manager approvals was around 25 days in 2025/26, within a statutory maximum of three months for a complete application. We agree the search timetable with you at briefing.

What happens if our MLRO leaves suddenly?

At SMCR firms, someone can provide temporary cover while the firm submits an application for a replacement within 12 weeks. Payment and e-money firms need to appoint a replacement and notify the FCA. Either way, call us early so the search runs alongside the cover.

How are Exec Capital’s fees structured for part-time MLRO hires?

The fee structure is agreed at briefing. For contractor, interim and fractional appointments the day rate includes our fee; for employed part-time appointments we agree retained or contingent terms with you before the search starts.