Upshift Finance
Fractional MLRO / Nominated Officer - Annex 1
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Company Description
Upshift Finance is a specialist SME lender providing flexible, structured capital to proven UK businesses, founded by former J.P. Morgan and Morgan Stanley investment bankers. The firm focuses on junior capital solutions, including unsecured revolving credit facilities and term loans from £100k to £2m+ with tenors of 1–24 months, for established businesses that have reached traditional leverage limits but remain strong credits. Backed by committed capital, Upshift Finance works alongside existing lenders to deliver additional funding when timing, structure, or complexity fall outside typical bank appetite. The company’s advantage lies in institutional-grade underwriting delivered at fintech speed, combining thorough credit work and clean documentation with decisions in days rather than weeks. This environment offers professionals exposure to sophisticated credit structures in a fast-paced, high-accountability setting.
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Role Description
We are preparing our application to register with the FCA as an Annex 1 financial institution under the Money Laundering Regulations 2017. We're appointing an experienced financial crime professional as our nominated officer (MLRO).
This is a genuinely fractional appointment: around three to four days a month once established, with more time in the first couple of months while we complete registration. It is largely remote, with board meetings and any FCA meetings in person in London. It would suit someone running a portfolio of MLRO or non-executive compliance roles, or a senior MLRO stepping back from a full-time seat.
We lend only to UK companies with UK based UBOs and do no consumer lending. Due diligence files are prepared in-house by our deal team. The role is judgement, challenge and sign-off, not processing. Because the appointment is part of our FCA application, we are moving quickly.
Requirements
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- Experience as an MLRO or nominated officer at a UK Annex 1 lender, bank or other FCA-registered or FCA-authorised firm, and comfortable being assessed and interviewed by the FCA.
- Direct experience of an FCA registration or authorisation, ideally as the named MLRO. Annex 1 experience is a strong plus.
- A lending background, such as SME or corporate lending, private credit, asset-based or specialty finance, or corporate banking. Retail-only experience won't suit this mandate.
- Sound judgement on complex ownership structures, beneficial ownership, and source of funds and wealth.
- Practical UK financial sanctions experience, including OFSI reporting.
- Hands-on experience of SARs and DAML requests to the NCA.
- UK-based, with the right to work in the UK.
Desirable
- Experience holding fractional, portfolio or non-executive compliance roles across several firms.
- A recognised AML qualification, such as the ICA Diploma.
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