We are delighted to be partnering with a high-growth Fintech start-up seeking to appoint a Money Laundering Reporting Officer (MLRO). This is a key hire and the role is of a remote nature with occasional travel to London as and when business needs arise. An equity component is offered in addition to a competitive salary.

Job Summary

The MLRO will be the firm’s statutory Head of Financial Crime Compliance, directly responsible for oversight of all anti-money laundering (AML), counter-terrorist financing (CTF), and sanctions compliance activities. The successful candidate will be instrumental in the FCA authorisation process, embedding a robust financial crime framework, and ensuring the firm meets all regulatory requirements under the Electronic Money Regulations 2011 (EMRs) and the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLRs).

Key Responsibilities:

Regulatory and Strategic

• FCA Licence Application: Act as the lead for all Financial Crime elements of the FCA EMI licence application, including drafting the Financial Crime Chapter of the Regulatory Business Plan, conducting gap analyses, and interacting with the FCA during the application process.
• Regulatory Accountability (SMF17): Hold the SMF17 designation, maintaining the required Statement of Responsibilities (SoR) and being personally accountable to the FCA for the firm's financial crime controls.
• Governance: Report directly to the Board of Directors on the effectiveness of AML/CTF systems and controls, at least annually.

AML/CTF Systems and Controls

• Risk Assessment: Develop, implement, and maintain the firm’s formal Money Laundering and Terrorist Financing Risk Assessment (MLTRA), ensuring it is current and covers all products, services, customers, and geographies.
• Policies & Procedures: Establish, implement, and maintain comprehensive, written AML/CTF policies, procedures, and controls, covering Customer Due Diligence (CDD), Enhanced Due Diligence (EDD), Sanctions screening, and transaction monitoring.
• Suspicious Activity Reports (SARs): Act as the statutory point of contact for external communication with the National Crime Agency (NCA), receiving internal suspicious activity reports, evaluating them, and submitting SARs to the NCA where appropriate.
• Transaction Monitoring: Oversee the design, tuning, and operation of the automated transaction monitoring systems, ensuring appropriate risk typologies are covered.
• Sanctions: Ensure the firm’s Sanctions screening program is effective, covering customers and transactions against global sanctions lists (OFSI, OFAC, UN, etc.).

Training and Culture

• Training: Develop and deliver mandatory, bespoke, risk-based AML/CTF training programs for all staff, management, and the Board of Directors, ensuring they understand their personal responsibilities.
• Oversight: Foster a strong financial crime compliance culture throughout the organisation.

Required Knowledge and Experience:

Category Requirement

• Experience: Minimum of 5 years of progressive experience in Financial Crime/AML Compliance within the UK financial services sector. Must have prior experience as a Money Laundering Reporting Officer (MLRO) or Deputy MLRO (DMLRO) in an FCA-regulated Payments Institution (PI) or Electronic Money Institution (EMI).
• Regulatory Deep, practical working knowledge of the MLRs 2017, EMRs 2011, Proceeds of Crime Act 2002 (POCA), and the FCA Handbook (especially SYSC and SM&CR rules).
• Technical: Proven experience in drafting and implementing AML/CTF policies, performing MLTRAs, managing Transaction Monitoring systems, and reporting to the NCA.

Qualifications: 

• A recognised AML/Financial Crime professional qualification (e.g., ACAMS, ICA Diploma in Anti-Money Laundering).

Skills:

• Excellent leadership, communication, and stakeholder management skills, capable of influencing the Board and challenging senior management.