Fractional MLRO / Nominated Officer - Annex 1 Firms (UK)
Capitex · Remote
Capitex is a specialist financial crime compliance firm. We are building a bench of experienced Money Laundering Reporting Officers to act as fractional MLROs / nominated officers for UK Annex 1 firms - lenders, leasing businesses, invoice and asset financiers, bridging lenders and private credit funds that are registered with, or applying to, the FCA under the Money Laundering Regulations.
Since the FCA's August 2026 statement on Annex 1 firms, demand for credible, independent MLROs has risen sharply. Most of these firms do not need a full-time hire. They need a named, experienced person for a few hours a month - more during registration or when a deal is onboarding - and they are paying properly for it.
This is not one vacancy. It is an ongoing series of assignments. If you are a good fit we will speak once, understand your capacity and sector preferences, and then bring you specific firms to consider. You choose which appointments you take.
What the role involves
- Acting as the firm's nominated officer under the Money Laundering Regulations 2017, named with the FCA
- For firms still applying: helping build the registration pack - business-wide risk assessment, AML policies and procedures, customer due diligence approach - and fronting the FCA's questions and interview
- For registered firms: owning the AML framework, reviewing and refreshing the risk assessment and policies, handling FCA information requests
- Receiving internal suspicious activity reports and making external reports to the NCA where required
- Oversight of onboarding and enhanced due diligence on higher-risk borrowers and beneficial owners
- Quarterly board reporting and the annual MLRO report
- Staff AML training where the firm wants it
How it works
- Fully flexible: typically 2 to 10 hours a month per firm, scaling up during registration or busy periods
- You can hold several appointments at once, subject to conflicts and your own capacity
- Remote by default, with occasional office visits - most clients are in London, the North West and the Midlands
- Paid per approved hour on a monthly timesheet, through your own limited company or an umbrella
- Capitex handles the client relationship, contracting, invoicing and payment
Requirements
- Substantial experience as an MLRO, deputy MLRO or nominated officer at a UK regulated or registered firm
- You have been through an FCA registration, authorisation or supervisory interview and know what the regulator expects
- Strong working knowledge of the Money Laundering Regulations 2017, JMLSG guidance, POCA and the SAR regime
- Able to write and own a business-wide risk assessment and a proportionate AML framework for a small, fast-moving lender - not a bank-sized manual
- Experience in one or more of: bridging and property finance, asset finance and leasing, invoice finance, commercial lending, private credit, payments or e-money
- Comfortable presenting to boards, founders and investors, and saying no when it is needed
- Clean regulatory record and willing to be named with the FCA
- Based in the UK with the right to work here
You may have held SMF17 at an authorised firm, or the MLRO role at a payments, e-money or lending business. Semi-retired, portfolio and interim professionals are very welcome - several of our current MLROs work this way.
Benefits
- Competitive hourly rates, agreed per assignment
- Choose your own workload and clients
- A steady flow of assignments from one relationship - we are speaking to new Annex 1 firms every week
- No business development, contracting or invoicing on your side
- Work with founders who want it done properly