Robert Half
Head of Compliance & MLRO (SMF16&17) - Peer 2 Peer lending firm
London
£140k – £170k/yr
Posted about 15 hours ago
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Head of Compliance & MLRO
Regulated Functions
- SMF16 (Compliance Oversight)
- SMF17 (Money Laundering Reporting)
Location
- London, UK (Hybrid)
Reporting To
- The Board
Firm Type
- Peer-to-Peer (P2P) Lending Platform
Role Purpose
Compliance Oversight (SMF16)
- Regulatory Leadership: Act as the primary point of contact for the FCA, managing regulatory submissions, notifications, thematic reviews, and routine correspondence.
- Framework Maintenance: Establish, review, and update compliance policies, procedures, and controls to ensure complete alignment with the FCA Handbook (specifically SYSC, SUP, DISP, and COBS 18.12).
- P2P-Specific Compliance: Oversee and validate compliance workflows unique to P2P platforms, including investor appropriateness assessments, high-net-worth/sophisticated investor categorisation, mandatory risk warnings, and marketing restrictions.
- Compliance Monitoring: Design, execute, and report on the annual Compliance Monitoring Programme (CMP) to detect, evaluate, and mitigate systemic or operational compliance risks.
- Board Advisory: Provide clear, actionable regulatory guidance to the Board of Directors regarding commercial strategy, product launches, operational changes, and structural risk management.
- Breaches & Complaints: Manage the log of regulatory breaches and oversee the investigation and resolution of customer complaints in accordance with DISP rules.
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Financial Crime Prevention & MLRO (SMF17)
- Financial Crime Strategy: Maintain and continuously enhance the firm’s Anti-Money Laundering (AML), Counter-Terrorist Financing (CTF), Sanctions, and Anti-Bribery policies in line with the Money Laundering Regulations and JMLSG guidelines.
- Risk Assessments: Perform and own the firm’s annual Financial Crime Risk Assessment, ensuring emerging typologies (especially regarding digital onboarding and alternative lending) are accounted for.
- SAR Management: Act as the ultimate internal authority for analyzing internal Suspicious Activity Reports (SARs) and executing external escalations to the National Crime Agency (NCA).
- Onboarding Oversight: Oversee the integrity of digital Know Your Customer (KYC), Know Your Business (KYB), and Customer Due Diligence (CDD) procedures for both platform retail/institutional investors and borrowers.
- Enhanced Due Diligence (EDD): Review and sign off on high-risk accounts, Politically Exposed Persons (PEPs), and complex corporate borrower structures.
- Reporting: Compile and present the annual MLRO Report directly to the Board of Directors, highlighting operational stats, risk positions, and mandatory recommendations.
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Culture, Training & Competence
- Training Delivery: Develop and execute an ongoing regulatory and financial crime training program for all staff, ensuring deep understanding of individual accountability under the Senior Managers and Certification Regime (SM&CR).
- Compliance Culture: Promote a positive, open compliance culture across the firm where regulatory consideration is integrated into product development and daily customer operations.
Candidate Profile & Qualifications
Experience & Technical Knowledge
- Regulated Environment: Experienced SMF16 & 17 within UK retail financial services, fintech, alternative credit, crowdfunding, or P2P lending.
- FCA Regime Expertise: Comprehensive, up-to-date knowledge of the FCA Handbook and practical implementation experience of SM&CR, Consumer Duty, and P2P-specific regulatory requirements.
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Skills
Compliance Oversight
Money Laundering Reporting
FCA Handbook
AML
CTF
KYC
KYB
CDD
SM&CR
Consumer Duty
Risk Assessment
SAR Management
Regulatory Reporting
Financial Crime Prevention
P2P Lending Compliance
Board Advisory
Location