Free cookie consent management tool by TermsFeed Generator Head of Compliance & MLRO SMF16/17 | Altum Consulting

Head of Compliance & MLRO SMF16/17

location: London

job type: permanent

salary: Negotiable

сonsultant: Luke Gilbert

date posted: 04/09/2026

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This is a senior SMF16 / SMF17-level appointment, reporting directly to the CEO and Board. The successful candidate will have significant influence over the firm's regulatory framework and will play a key role in its ongoing development and future FCA authorisation strategy.

We are particularly interested in candidates who have previously held FCA approval as SMF16 and/or SMF17, ideally within an EMI, Payment Institution or UK payments business.

The role:

The successful candidate will initially undertake a substantive review of the existing compliance and financial crime framework, identify areas requiring remediation and take ownership of the resulting framework.

A major element of the role will be leading the compliance and financial crime workstream supporting the firm's future Authorised Electronic Money Institution (AEMI) application, including direct engagement with the FCA.

  • Lead the Compliance and Financial Crime functions with appropriate independence and authority.
  • Undertake responsibilities associated with SMF16 - Compliance Oversight and SMF17 - MLRO, subject to FCA approval where applicable.
  • Provide direct regulatory advice, challenge and reporting to the CEO and Board.
  • Own and maintain the firm's regulatory compliance framework, policies, procedures and monitoring programme.
  • Own the firm's AML/CTF, sanctions, fraud, proliferation-financing and wider financial crime framework.
  • Review and maintain the Business-Wide Risk Assessment (BWRA) and associated methodologies.
  • Oversee CDD/EDD, PEP and sanctions screening, transaction monitoring, ongoing monitoring and SAR governance.
  • Ensure compliance and financial crime controls are effectively implemented, tested and evidenced.
  • Produce Board-level compliance and MLRO reporting, MI and risk indicators.
  • Provide oversight of safeguarding, Consumer Duty, APP fraud, outsourcing and operational resilience requirements.
  • Monitor regulatory developments and ensure the business remains aligned with applicable FCA requirements.
  • Lead compliance and financial crime input into the firm's FCA AEMI authorisation process.
  • Review existing application documentation, identify deficiencies and oversee remediation.
  • Lead responses to FCA requests for information and participate in FCA meetings and interviews.
  • Act as a senior regulatory contact and ensure submissions and responses are accurate, complete and appropriately evidenced.
  • Promote a strong compliance and financial crime culture across the organisation.

Particularly Relevant Experience:

  • Previous FCA approval as SMF16 and/or SMF17.
  • Experience personally discharging both Compliance Oversight and MLRO responsibilities.
  • Previous experience within an EMI, AEMI or Payment Institution.
  • Experience leading or materially supporting an FCA EMI authorisation application.
  • Experience navigating FCA interviews and detailed regulatory scrutiny.
  • Experience joining a business during a period of authorisation, remediation or significant regulatory change.
  • Experience independently reviewing and taking ownership of a compliance framework developed by a predecessor.
  • Knowledge of safeguarding, Consumer Duty, APP fraud, outsourcing and operational resilience.

This role would suit a senior compliance professional who is comfortable operating with significant autonomy and who can confidently engage with the FCA, CEO and Board.

You will need to demonstrate:

  • Strong regulatory judgement and independence.
  • The confidence to challenge senior stakeholders where required.
  • Excellent written and verbal communication skills.
  • A pragmatic, commercially aware approach to regulation.
  • Strong ownership and accountability.
  • The ability to operate effectively within a growing fintech environment without compromising control-function independence.

This is not an entry-level MLRO or general compliance management position.


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