Responsibilities
MLRO Deputisation and Governance
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Act as alternate nominated officer, deciding on SARs and DAML requests when the MLRO is unavailable, under documented delegated authority.
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Attend the Audit, Risk and Compliance Committee and the Group Financial Crime Committee in the MLRO's absence.
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Maintain a complete, contemporaneous audit trail of all decisions taken under deputised authority, distinct from decisions taken by the MLRO.
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Maintain deputisation readiness: current knowledge of the MLRO's live case load, open regulator correspondence and outstanding remediation, so cover can be provided at short notice.
Suspicious Activity Reporting and Sanctions
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Oversee escalations from transaction monitoring and name screening (PEP, sanctions, adverse media), setting investigation quality and disposition standards.
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Oversee sanctions screening escalations and prepare OFSI reports for MLRO sign off.
Financial Crime Framework
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Maintain the Business Wide Risk Assessment (BWRA), proliferation financing risk assessment, AML, CTF and CPF policies and the customer risk assessment methodology, and propose changes to the MLRO for approval.
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Escalate material gaps or emerging typologies to the MLRO.
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Lead root cause analysis on control failures or thematic issues and track remediation actions to closure.
Regulatory Reporting and Regulator Engagement
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Prepare financial crime MI for senior management and governance committees, and draft sections of the annual MLRO Report.
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Support responses to FCA information requests and assist with skilled person reviews (s.166 FSMA 2000) or supervisory visits as directed by the MLRO.
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Track the AML control framework against FCA Handbook updates, JMLSG guidance revisions and OFSI and HMT sanctions notices.
Team Leadership and Succession
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Line manage members of the UK Financial Crime team, setting quality standards, coaching and development plans.
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Act as the escalation point for complex or ambiguous cases referred by Level 1 and Level 2 analysts and more junior members of the UK Financial Crime team.
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Build the knowledge and judgement needed to step up to SMF1
Requirements
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Deep working knowledge of UK AML and CTF regulation: MLR 2017, POCA 2002, TA 2000, FCA SYSC 6.3 and JMLSG Guidance.
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Sound judgement under pressure. Comfortable taking disposition decisions on live SARs without the MLRO present.
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Strong report writing and Board level communication skills.
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People leadership experience, or clearly demonstrated readiness to lead a team.
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Ability to manage regulator facing deliverables to deadline.
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5+ years in AML and financial crime compliance within a regulated firm (CFD or brokerage, banking, payments or crypto), or equivalent regulatory exposure, including direct SAR investigation and disposition experience.
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Prior deputy or MLRO experience is preferred but not required.
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Experience preparing MI for Boards or Risk Committees.
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Familiarity with CFDs, spread betting and margin trading behaviours.
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Awareness of how FCA Consumer Duty intersects with financial crime risk (for example, vulnerable customer considerations in AML decisioning).
Nice to Have
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ICA Diploma or Advanced Certificate in AML, ACAMS or equivalent.
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Direct exposure to FCA supervisory engagement
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Existing line management experience.