Engagement Type: Initially Fractional/Advisory (1–2 days/week), transitioning to Full Time through stage gates.
Purpose
Act as Compliance Officer and MLRO for the FCA application, creating the compliance, AML, and financial crime frameworks required for authorisation and early operations.
Key: Named Individual on FCA Application
About the Company
The company is an early‑stage fintech, focused on providing streamlined business financing solutions. Its model combines modern underwriting, data‑driven credit assessment, and simple digital onboarding to deliver fast, transparent access to working capital. As the firm prepares for FCA authorisation and initial market launch, it is building a lean leadership structure with experienced specialists in finance, compliance, and risk to ensure high standards of governance from day one.
Role Summary
Starting as an advisor, this role provides senior regulatory input into the FCA application, policy suite, and early‑stage control design. Once the business launches and scales, the role transitions into a full‑time employee as MLRO & Compliance Officer.
Key Responsibilities
Phase 1 — Advisory / Fractional (Pre‑Licence & Early Operations)
– Lead compliance and financial crime components of the FCA application; act as named individual (Compliance Officer / MLRO).
– Draft, refine, and implement the compliance and AML frameworks (AML/CTF, sanctions, onboarding/KYC, fraud, conduct, governance, SARs).
– Produce the Business‑Wide Risk Assessment, monitoring plan, registers, and policy documentation.
– Support vendor selection for KYC, transaction monitoring, and sanctions screening tools.
– Prepare the team for supervisory interaction and post‑authorisation obligations.
Phase 2 — Full Time (Stage‑Gate Triggered)
– Manage day‑to‑day compliance operations and AML oversight.
– Serve as primary contact with FCA on all supervisory matters.
– Maintain registers, MI, complaints, regulatory reporting, and monitoring cadence.
– Lead thematic reviews, internal audits, and testing of the control environment.
– Build out the compliance function as customer activity increases.
– Stage Gates for Transition to Full Time
FCA authorisation granted.
– Go‑live customer onboarding (“Day 1” operations).
– Transaction volumes reach defined thresholds requiring daily AML/compliance presence.
– Internal review confirms increased operational demand.
Required Experience
– MLRO / Deputy MLRO experience in fintech, lending, payments, or digital financial services.
– Deep knowledge of FCA Handbook (SYSC, CONC, financial crime, MLR 2017).
– Confident operating independently in an early‑stage environment.
Expected Outcomes
– Complete and scalable compliance + AML framework.
– Smooth, high‑quality FCA authorisation process.
– Robust ongoing compliance function ready for transaction growth.
Please get in touch with us on info@projectbrains.io
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