Specialists in the MLRO appointment
MLRO Capital is the FD Capital Group site dedicated to money laundering reporting officers and the financial crime teams around them. It gives firms a direct route to the specialists who run MLRO searches every week, without having to work out which of our practices to call.
Part of FD Capital Group
FD Capital Group is a network of five specialist recruitment practices, each focused on a different tier of senior appointment. FD Capital places finance directors and CFOs. Exec Capital handles C-suite and board-level executive search. NED Capital finds non-executive directors and chairs. Accountancy Capital recruits qualified finance professionals below director level. SMF Capital recruits Senior Manager Function holders for FCA and PRA-regulated firms.
MLRO Capital exists because the MLRO is the hire regulated firms ask us about most. Across the group, combined compliance officer and MLRO roles, fractional MLROs and interim cover after a sudden resignation make up a large share of our regulated enquiries. Those firms come from very different sectors: payments, e-money and crypto-asset firms, wealth managers, lenders, brokers and insurers. What they share is a single, demanding appointment.
When a firm gets in touch through MLRO Capital, the search is delivered by SMF Capital, the group’s specialist practice for regulated appointments. If the hire turns out to be a chief risk officer, a finance director or a non-executive, the right practice takes it and we make the introduction ourselves. You deal with one team throughout.
The same applies to candidates. An MLRO who registers through MLRO Capital joins the group’s central candidate database, so they are considered for MLRO roles at SMF Capital, compliance and financial crime roles at FD Capital, and board roles at NED Capital without registering again. For firms, that means a wider pool on every search; for candidates, it means one confidential conversation rather than five.
MLRO Capital at a glance
- Focused on MLROs, deputy MLROs and financial crime leaders
- Searches delivered by SMF Capital
- SMF17 roles and MLROs at firms outside the Senior Managers regime
- Permanent, interim and fractional appointments
- Every search led personally by Adrian Lawrence FCA
- Offices in London and the West Midlands
The hardest seat in the second line to fill well
The MLRO role has a narrower candidate pool, higher personal stakes and more sector-specific risk than almost any other senior hire. A generalist search tends to miss all three.
Personal stakes
As nominated officer, the MLRO can face criminal liability under the Proceeds of Crime Act 2002 for failing to report. At SMCR firms they also hold SMF17 and the Duty of Responsibility. Strong candidates scrutinise the firm’s controls, culture and resourcing before they accept, and the search has to answer their questions honestly.
Sector-specific risk
Payments fraud, sanctions exposure, source of wealth, crypto-asset flows and trade-based laundering each call for different experience. We match candidates on the risks they have actually managed, not on the size of their last employer.
Regulatory scrutiny
The FCA looks hard at MLROs, especially at payments, e-money and crypto-asset firms and at firms seeking authorisation. A candidate who cannot evidence challenge, escalation and sound reporting judgement can hold up an approval or an application.
The MLRO and the team around it
| Role | Regulatory basis | How firms usually hire it | Where to read more |
|---|---|---|---|
| MLRO at an SMCR firm | SMF17, FCA approval required | Permanent at larger firms, fractional at smaller ones | MLRO recruitment (SMF17) |
| MLRO at a payments, e-money or crypto-asset firm | Money Laundering Regulations 2017 | Permanent or fractional, closely assessed by the FCA | Payments and fintech |
| Compliance officer and MLRO | SMF16 and SMF17 held together | The default at most small and mid-sized firms | Combined role recruitment |
| Interim MLRO | SMF17 cover under the 12-week rule, or MLR cover | Vacancies, remediation and skilled person reviews | Interim MLRO |
| Deputy MLRO | Firm’s own arrangements for absence cover | Permanent, often a step towards a first MLRO role | Do you need a deputy MLRO? |
| Head of financial crime, sanctions lead | Certification Regime at many firms | Permanent, sized to the firm’s risk | Financial crime leadership |
For a full explanation of the role, read the MLRO role explained or FD Capital’s complete UK MLRO guide.
Our standards on every MLRO search
We test judgement, not just experience
Years in financial crime tell you little about how someone makes a reporting decision under pressure. We ask candidates to walk through real decisions, how they documented them and what happened next, and we check those accounts against references. The FCA’s Financial Crime Guide gives a useful picture of the standard regulators expect.
Regulatory readiness first
For SMF17 roles, we test candidates against the FCA’s fit and proper criteria before they reach you, and request regulatory references covering the previous six years as soon as a candidate is serious. Our guide to the fit and proper test explains each criterion.
Honest advice on structure
Sometimes the right answer is a fractional MLRO with a strong deputy, or splitting a combined SMF16/17 role, rather than the hire the firm first asked for. We will say so. Our governance and SMF structure review is built for that conversation.
Discretion
Replacing an MLRO can be sensitive inside the firm and with its supervisor. We approach candidates without naming the client until the right point, and the search stays confidential throughout.
Our team
Everyone on the FD Capital Group team has worked in senior-level recruitment for at least ten years, and each practice’s network of senior executives, many of whom also hold non-executive roles, is pooled across the group. An MLRO who has worked with one of our FD Capital clients, or a financial crime leader who sits on a board we recruited for, is within reach of every MLRO Capital search.
Where we are
London: 167–169 Great Portland Street, London W1W 5PF
West Midlands: Watling Court, Orbital Plaza, Watling Street, Cannock WS11 0EL
We recruit MLROs across the UK, with dedicated pages for London, Birmingham, Manchester, Leeds, Bristol and Edinburgh.
Practical guidance on financial crime hiring
MLRO Capital publishes articles on the decisions firms face around their MLRO: when a fractional appointment works, how to size a financial crime team, what to look for in a crypto-asset MLRO, how the board should read the annual MLRO report, and how new offences such as failure to prevent fraud change the brief.
For reference material, the SMF Capital Knowledge Centre covers suspicious activity reports and the nominated officer, customer due diligence and the business-wide risk assessment.
The primary sources are worth knowing too. The Money Laundering Regulations 2017 set out the nominated officer and risk assessment requirements, the JMLSG guidance explains how the financial sector applies them, and the National Crime Agency publishes guidance on making good quality reports.
Adrian also discusses MLRO and Senior Manager appointments on the SMF Unlocked podcast, available on Apple Podcasts and through the SMF Capital media centre.
About working with us
Is MLRO Capital a separate company?
No. MLRO Capital is part of the FD Capital Group network. MLRO searches are delivered by SMF Capital, a trading name of FD Capital Recruitment Ltd, so your contract, terms and point of contact are with SMF Capital.
Why does my enquiry go to SMF Capital?
Because SMF Capital is the group’s specialist practice for regulated appointments, and it runs MLRO searches every week. Routing MLRO enquiries there means you get the same fit and proper process, the same candidate network and the same team.
Do you recruit MLROs for firms outside financial services?
Our focus is FCA-regulated firms and firms supervised by the FCA under the Money Laundering Regulations, including payments, e-money and crypto-asset businesses. If your firm is supervised by another body, talk to us and we will tell you honestly whether we are the right fit.
Can you help a firm applying for authorisation?
Yes. An application needs a credible MLRO named on it, and the FCA will assess that person closely. See SMF authorisation support and building an SMF team from scratch.
How do I register as an MLRO candidate?
Use the SMF Capital candidate registration page. Registration covers every FD Capital Group practice, so you only need to register once.
Talk to us about your MLRO hire
Tell us about the firm, its permissions and your timing. We will come back to you the same working day.