Money Laundering Reporting Officer (MLRO)

Remote | Permanent, Full-Time

About the job

Birchlake Recruitment is delighted to be partnering with digital financial platform and payment solutions provider to appoint a Money Laundering Reporting Officer (MLRO) as the business progresses through its FCA authorisation journey.

This is a key senior appointment within a growing start-up, with responsibility for leading the firm's financial crime function and acting as the internal lead for the EMI authorisation process.

The successful candidate will work closely with an external regulatory consultancy supporting the EMI application, providing internal ownership, oversight and challenge throughout the process. You will be responsible for ensuring the application is appropriately coordinated across the business, that the external partner's work is robust and aligned with the firm's requirements, and that the business is able to respond confidently and effectively to the FCA.

The successful candidate must demonstrate the ability and willingness to develop a strong working knowledge of the Electronic Money Regulations 2011 (EMRs) and the regulatory requirements applicable to an EMI. They will be expected to proactively close any knowledge gaps before taking full responsibility for leading the relevant aspects of the authorisation process.

As SMF 17, you will also hold significant regulatory accountability for the firm's financial crime arrangements, working closely with the board and senior management to establish and embed a robust Financial Crime Framework from the outset.

What you'll bring to the role:

FCA Authorisation & Regulatory Leadership

• Act as the internal lead for all financial crime aspects of the firm's FCA EMI authorisation application.
• Work closely with the external regulatory partner supporting the application, providing effective oversight, review and constructive challenge of their work.
• Ensure the financial crime elements of the application are accurate, comprehensive and aligned with the firm's business model and regulatory requirements.
• Coordinate the application internally, working with senior management and relevant business functions to ensure information, documentation and responses are delivered effectively and on time.
• Develop a strong practical understanding of the Electronic Money Regulations 2011 (EMRs) and other regulatory requirements relevant to the firm's EMI application.
• Proactively identify and close any gaps in your knowledge of EMI requirements before assuming full responsibility for leading the authorisation process.
• Engage confidently with the FCA, responding to regulatory queries and providing clear, well-considered information throughout the application and supervisory process.
• Maintain the firm's SMF 17 designation, statement of responsibilities and associated regulatory accountabilities.
• Provide strategic advice and challenge to the board and senior management on financial crime and regulatory matters.

Financial Crime Framework

• Develop, implement and maintain the firm's Financial Crime Framework, covering AML, CTF, sanctions, fraud and related financial crime risks.
• Establish and maintain the firm's Money Laundering and Terrorist Financing Risk Assessment (MLTRA), ensuring it reflects the firm's products, services, customers and geographical exposure.
• Develop and maintain comprehensive AML/CTF policies, procedures and controls covering customer due diligence (CDD), enhanced due diligence (EDD), sanctions screening and transaction monitoring.
• Ensure financial crime controls are appropriately designed, documented, monitored and regularly reviewed.
• Identify emerging financial crime risks and ensure appropriate controls and mitigations are implemented.
• Ensure the financial crime framework remains proportionate and effective as the business develops and grows.

SARs, Transaction Monitoring & Sanctions

• Act as the firm's primary point of contact with the National Crime Agency (NCA) in relation to suspicious activity reporting.
• Receive and assess internal suspicious activity reports and determine whether external suspicious activity reports (SARs) should be submitted.
• Oversee the design, implementation and ongoing effectiveness of the firm's transaction monitoring framework and systems.
• Ensure transaction monitoring appropriately reflects relevant financial crime typologies and the firm's risk profile.
• Maintain effective sanctions screening arrangements, covering customers and transactions against applicable sanctions regimes and relevant sanctions lists.
• Oversee financial crime investigations and regulatory notifications where required.

Governance, Training & Culture

• Provide regular and meaningful reporting to the board of directors on the effectiveness of the firm's AML/CTF systems and controls.
• Develop and deliver appropriate, risk-based AML and financial crime training for employees, management and the board.
• Ensure employees understand their responsibilities in relation to financial crime prevention and regulatory compliance.
• Promote a strong culture of financial crime awareness, accountability and compliance throughout the organisation.
• Establish appropriate governance, MI and escalation arrangements to support effective decision-making.
• Work collaboratively with the wider management team, recognising that successful FCA authorisation requires coordinated input and ownership across the business.

About you:

Vital:

• A minimum of 5 years' experience within financial crime / AML compliance in the UK financial services sector.
• Previous experience operating as an MLRO or Deputy MLRO (DMLRO) within an FCA-regulated financial services organisation.
• Strong practical knowledge of the Money Laundering Regulations 2017 (MLRs), Proceeds of Crime Act 2002 (POCA) and relevant FCA requirements.
• A strong understanding of SM&CR, including the responsibilities associated with SMF 17.
• Proven experience developing and implementing AML/CTF frameworks, policies and controls.
• Experience completing MLTRAs, overseeing transaction monitoring and sanctions screening programmes, and managing SARs and NCA reporting.
• Demonstrable experience engaging with the FCA or other relevant regulatory bodies, with the confidence to communicate effectively at a senior level.
• The ability to take internal ownership of a regulatory authorisation or significant regulatory project, coordinating multiple stakeholders and ensuring delivery against regulatory expectations.
• Strong analytical and critical-thinking skills, with the ability to review, challenge and quality-assure the work of external advisers or consultants.
• Strong leadership, communication and stakeholder management skills, with the ability to influence and constructively challenge senior management and the Board.
• A proactive approach to professional development, with the ability to quickly develop and demonstrate a strong working knowledge of the EMRs and EMI-specific regulatory requirements where this experience has not previously been gained.

Desirable:

• Previous experience within a Payments Institution (PI), Electronic Money Institution (EMI), fintech or other regulated payments environment.
• Previous involvement in an FCA authorisation, variation of permission or regulatory application process.
• Experience working within a start-up, scale-up or newly established financial services business.
• Experience working with external regulatory consultants or professional advisers and effectively overseeing their deliverables.
• Experience developing and embedding a Financial Crime Framework within a new or rapidly growing organisation.
• Professional qualification such as ACAMS, ICA Diploma in Anti-Money Laundering or equivalent.

What you'll get in return:

• Fully remote working
• Flexible working / flexitime
• Permanent, full-time position
• Significant involvement in the FCA EMI authorisation process
• The opportunity to work closely with senior management and external regulatory specialists
• A highly visible role with genuine influence over the firm's regulatory and financial crime framework

If you're an experienced MLRO or DMLRO with strong financial crime expertise and the ability to take ownership of a regulatory authorisation process, we'd love to hear from you.

Apply today or contact Birchlake Recruitment for a confidential discussion about the role.