MLRO - UK

Responsibilities:

• MLRO Duties
• Serve as the firm’s nominated officer under Regulation 21 of the Money Laundering Regulations 2017 (as amended) (the “MLR”).
• Maintain and oversee the firm’s AML/CTF/CPF compliance framework, including compliance policies and processes, ensuring alignment with the MLR, FCA expectations and the FCA Financial Crime Guide (“FCG”).Oversee the firm’s enterprise-wide risk assessment (“EWRA”), customer risk assessments, and enhanced due diligence for higher-risk relationships.
• Receive, assess, and investigate internal Suspicious Activity Reports (SARs) and determine when to escalate to the NCA.
• Design and oversee the implementation of appropriate AML/CFT monitoring systems and controls, in the context of outsourcing day-to-day financial crime processes.
• Ensure robust training programmes for employees, including bespoke sessions for front-line, onboarding, and marketing staff, as required.
• Report regularly to the Board on the firm’s financial crime risk exposure, control effectiveness, and key metrics.
• Financial Promotions & Regulatory Compliance
• Oversee and advise on compliance with the UK Financial Promotions Regime under section 21 of FSMA and relevant FCA rules.
• Ensure all cryptoasset financial promotions comply with the FCA’s fair, clear, and not misleading standard, mandatory risk warnings, and consumer categorisation rules.
• Collaborate with Marketing, Product, and Legal teams to ensure that promotions are approved, documented, and monitored.
• Maintain an up-to-date understanding of the cryptoasset financial promotions regime, including changes under the new section 21 approver regime and CP25/25 Handbook applications.
• Support readiness for future cryptoasset-specific rules under CP25/25, including Consumer Duty, etc.
• Advise the firm on emerging AML/CFT/CPF and cryptoasset regulation trends.
• Provide subject-matter expertise to the Board and senior management on FCA financial crime expectations, Cryptoasset AML registration, and FSMA authorisation processes.

Requirements:

• Minimum 6 years’ experience as an MLRO or Deputy MLRO within a regulated financial services or cryptoasset business.
• Deep knowledge of UK AML/CTF regulations (MLR, Proceeds of Crime Act 2002, Sanctions and Anti-Money Laundering Act 2018).
• Demonstrated experience with the UK Financial Promotions Regime, ideally including cryptoasset or high-risk investment promotions.
• Proven engagement with the FCA, including in relation to AML supervision, regulatory reporting, or authorisation processes.
• Working knowledge of blockchain technology, digital assets, and associated AML typologies.
• Strong understanding of FSMA, SYSC, COCON, SM&CR, and the FCA’s FCG.
• Ability to work independently in a fast-paced, global organisation maintaining close contact with relevant teams across multiple locations.
• Excellent problem solving skills and ability to provide useful and efficient counsel.
• Good understanding in performing risk assessments, periodic/trigger reviews and enhanced due diligence.
• Curious to learn independently and confident to ask questions to achieve the best results.
• Proactive and self-oriented, diligent team player.
• Professional qualifications such as ICA Diploma in AML, CAMS, or equivalent are highly desirable.

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