FCA Authorisation & Regulatory Engagement

The successful candidate will play a central role in IPBPAY's FCA AEMI authorisation process and will:

• Take senior compliance ownership of the future AEMI application.
• Act as a principal FCA contact on compliance and financial crime matters as authorised by the Firm.
• Undertake a substantive review of existing application documentation and supporting evidence.
• Review AML/CTF and proliferation-financing risk assessments, methodologies and supporting evidence.
• Assess the policies, controls and procedures supporting those assessments and their practical implementation.
• Identify deficiencies and oversee remediation before a new application is submitted.
• Ensure application documents accurately reflect the arrangements the Firm intends to operate.
• Work with the CEO, Board, CFO and senior management to ensure consistency between the application, business model, financial projections, governance and operational arrangements.
• Lead compliance and financial crime responses to FCA RFIs.
• Prepare for and participate in FCA interviews and regulatory meetings.
• Ensure regulatory submissions within the role's remit are accurate, complete, supportable and appropriately evidenced.
• Take genuine professional ownership of the compliance and financial crime framework before the Firm returns to the FCA.

Governance & Board Responsibilities

• Attend relevant Board and senior governance meetings.
• Produce regular written Compliance and MLRO reports.
• Escalate material regulatory and financial crime risks promptly.
• Advise the CEO and Board on regulatory implications of strategic and operational decisions.
• Ensure compliance issues have clear ownership, remediation actions and deadlines.
• Maintain appropriate independence of the Compliance and MLRO functions.
• Support clear responsibilities, reporting lines and escalation arrangements.
• Ensure regulatory challenge and management responses are appropriately documented.
• Promote a strong compliance and financial crime culture throughout the Firm.

Safeguarding, Outsourcing & Operational Resilience

• Provide compliance oversight and challenge of the Firm's safeguarding framework.
• Work with Finance and the Board on safeguarding governance, controls, reconciliations and escalation.
• Maintain detailed knowledge of regulatory requirements applicable to electronic money and payment services.
• Provide oversight of payment operations, fraud prevention and APP fraud requirements where applicable.
• Oversee compliance aspects of material outsourcing and third-party arrangements.
• Assess regulatory risks associated with critical service providers.
• Support the Firm's operational resilience framework and provide appropriate regulatory challenge.

Essential Experience

Candidates must demonstrate:

• Extensive senior UK regulatory compliance and financial crime experience, normally 8+ years, with significant leadership responsibility.
• Substantial practical experience performing responsibilities associated with SMF16 and SMF17.
• Previous experience as an MLRO, Head of Compliance, Compliance Director or equivalent senior control-function leader.
• Demonstrable experience owning regulatory compliance and financial crime frameworks.
• Strong knowledge of the Electronic Money Regulations 2011, Payment Services Regulations 2017 and Money Laundering Regulations 2017.
• Detailed practical knowledge of AML/CTF, proliferation financing, sanctions, fraud and financial crime risk management.
• Experience developing, reviewing and owning BWRAs and associated methodologies.
• Experience implementing and evidencing financial crime policies, controls and procedures in practice.
• Direct FCA engagement experience, including regulatory correspondence, RFIs, supervisory engagement and/or interviews.
• Experience reporting directly to Boards and senior management.
• Demonstrable independence, regulatory judgement and ability to provide effective challenge.

Strongly Preferred

• Previous FCA approval as SMF16 and/or SMF17 within an EMI, Payment Institution or other FCA-regulated financial services firm is strongly preferred, together with demonstrable experience personally discharging the responsibilities of both Compliance Oversight and MLRO functions.

Highly Desirable

• Senior Compliance/MLRO experience within an EMI, AEMI, Payment Institution or UK payments business.
• Experience leading or materially supporting an FCA EMI/AEMI authorisation application.
• Experience navigating FCA interviews and detailed regulatory scrutiny.
• Experience joining a firm during authorisation, remediation or significant regulatory change.
• Experience independently reviewing and taking ownership of a framework developed by a predecessor.
• Safeguarding, Consumer Duty and APP fraud experience.
• Outsourcing, third-party risk and operational resilience experience.
• Experience within a growing fintech or payments organisation.

Qualifications

• Degree in law, finance, economics, business, risk, compliance or a relevant discipline, or equivalent senior professional experience.
• Professional qualification such as ICA, CAMS or equivalent is highly desirable.
• Appropriate continuing professional development.

Personal Attributes

• High integrity and sound regulatory judgement.
• Strong independence of thought.
• Confidence operating directly with the FCA, CEO and Board.
• Ability to challenge constructively and escalate where necessary.
• Excellent written and verbal communication skills.
• Strong analytical capability and attention to detail.
• Practical and proportionate approach to regulation.
• Strong ownership and accountability.
• Ability to operate effectively within a growing organisation while maintaining control-function independence.

Candidate Profile

This is not an entry-level MLRO or general compliance management role. IPBPAY requires an established senior compliance professional with the experience, authority, independence, capacity and judgement to take genuine ownership of the Firm's compliance and financial crime arrangements.