Altum Consulting
Head of Compliance & MLRO SMF16/17
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Senior Compliance and Financial Crime Leader
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:
- Initial Review and Ownership: 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.
- Compliance and Financial Crime Leadership: 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.
- Function Leadership: Lead the Compliance and Financial Crime functions with appropriate independence and authority.
- Regulatory Responsibilities: Undertake responsibilities associated with SMF16 - Compliance Oversight and SMF17 - MLRO, subject to FCA approval where applicable.
- Regulatory Advice and Reporting: Provide direct regulatory advice, challenge and reporting to the CEO and Board.
- Framework Maintenance: Own and maintain the firm's regulatory compliance framework, policies, procedures and monitoring programme.
- Financial Crime Management: Own the firm's AML/CTF, sanctions, fraud, proliferation-financing and wider financial crime framework.
- Risk Assessment: Review and maintain the Business-Wide Risk Assessment (BWRA) and associated methodologies.
- Monitoring and Governance: Oversee CDD/EDD, PEP and sanctions screening, transaction monitoring, ongoing monitoring and SAR governance.
- Compliance Assurance: Ensure compliance and financial crime controls are effectively implemented, tested and evidenced.
- Reporting and Indicators: Produce Board-level compliance and MLRO reporting, MI and risk indicators.
- Oversight and Compliance: Provide oversight of safeguarding, Consumer Duty, APP fraud, outsourcing and operational resilience requirements.
- Regulatory Alignment: Monitor regulatory developments and ensure the business remains aligned with applicable FCA requirements.
- Authorisation Process: Lead compliance and financial crime input into the firm's FCA AEMI authorisation process.
- Documentation and Remediation: Review existing application documentation, identify deficiencies and oversee remediation.
- FCA Engagement: Lead responses to FCA requests for information and participate in FCA meetings and interviews.
- Regulatory Submissions: Act as a senior regulatory contact and ensure submissions and responses are accurate, complete and appropriately evidenced.
- Culture Promotion: Promote a strong compliance and financial crime culture across the organisation.
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Particularly Relevant Experience:
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- 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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