Capitex
Fractional MLRO / Nominated Officer - Annex 1 Registration
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Description
A London-based private credit fund is appointing an experienced financial crime professional to act as nominated officer across two lending entities registering with the Financial Conduct Authority as Annex 1 financial institutions.
This is a genuinely fractional appointment - two to three days per month, flexible scheduling, remote with occasional attendance in Central London. It suits someone operating a portfolio of non-executive or fractional compliance engagements, or a senior MLRO stepping back from a full-time seat.
The business is a private credit fund lending to UK corporates, backed by an institutional investor, with a team of approximately ten. It completes around three transactions a year, ranging from £10m to £150m and typically between £20m and £50m, predominantly junior and mezzanine debt to corporate borrowers. There is no retail lending, no consumer exposure, and no transaction-level monitoring. Due diligence is prepared in-house by the deal team.
The role is oversight and judgement, not operational processing. The appointment is currently gating an FCA submission, so we are moving quickly.
The role
- Act as nominated officer under Regulation 21(3) of the Money Laundering Regulations 2017 for both registering entities, named on each application and subject to the FCA's assessment of fitness and propriety via the MLR Individual form
- Review, challenge and sign off customer due diligence files prepared by the deal team, covering group structure, directors, ultimate beneficial owners and controlling parties
- Validate risk ratings, determine where enhanced due diligence is required, and approve escalations, overrides and red flags in line with policy
- Own the annual KYC and AML refresh, including change of ownership and control triggers under facility agreements
- Take suspicious activity reporting decisions and submit to the NCA where required
- Oversee sanctions screening and OFSI reporting obligations
- Contribute to the business-wide risk assessment, policies and controls, working alongside the firm's external compliance consultancy through the registration process
- Provide periodic management information and board reporting on financial crime matters
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Reporting to the board. Overall responsibility for the firm's compliance under Regulation 21(1)(a) remains with an internal senior manager, and an internal deputy nominated officer is in place.
Requirements
- Demonstrable experience as an MLRO or nominated officer, of sufficient standing to satisfy the FCA's fitness and propriety assessment
- Direct experience of Annex 1 registration under the Money Laundering Regulations 2017, ideally having taken a firm through the application process
- Lending background - private credit, specialty finance, asset-based lending, corporate or wholesale banking. Retail-only backgrounds are not suited to this mandate
- Sound judgement on corporate structures, ultimate beneficial ownership and source of funds in a complex-ownership lending context
- Right to work in the UK
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Desirable:
- Experience acting in a fractional, portfolio or non-executive compliance capacity across more than one firm
- Familiarity with private credit fund structures and institutional or sovereign wealth backing
Benefits / engagement terms
- Engaged on contract through Capitex. Hourly, all-inclusive, billed against approved timesheets. No minimum term
- Two to three days per month with flexible scheduling, suited to concurrent engagements
- Concurrent engagements are expected and accommodated, subject to a written conflicts declaration
- Pre-engagement screening applies: identity, right to work, employment references, basic DBS and credit check
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