Location: London (hybrid)
Engagement: Long-term fractional, one day a week: leading the FCA application, then continuing as Head of Compliance & MLRO
Sector: Payments technology
Rate: Competitive day rate, dependent on experience
Role
Our client is a London-based payments technology company providing embedded payments to venues. The business is led by a founder with deep technical knowledge of payment gateways and card processing, and it now needs to apply to the Financial Conduct Authority (FCA) to become an Authorised Payment Institution (API).
The founder is strong on the technology and new to the regulator, and the application has yet to be written. The business needs an experienced compliance professional who can lead and write it, take ownership of the regulatory frameworks behind it and coach the leadership team through the FCA's questions. Once authorisation is granted, you will continue in the role as the firm's Head of Compliance & MLRO, running the compliance function on an ongoing fractional basis.
This is a hands-on, long-term fractional role in a small, founder-led team, working one day a week. You will work directly with the CEO and the board, and you will be named in the application as one of the people responsible for the firm's regulated services.
orisation application, from the business plan and programme of operations to the policies, financial forecasts and individuals' forms, through to submission and approval
Act as the firm's regulatory lead in dealings with the FCA, respond to requests for information, and prepare the founder and board for regulator questions and meetings
Design and build the safeguarding framework in line with the FCA's safeguarding rules (CASS 15, introduced by PS25/12), including reconciliation, the resolution pack and audit arrangements
Design and build the anti-money-laundering and counter-terrorist-financing framework, including the business-wide risk assessment, policies, procedures, customer due diligence and transaction monitoring
Confirm the payment services being applied for and document the flow of funds, including the role of third-party acquiring and processing partners
Prepare the governance documents the FCA expects, including the wind-down plan, outsourcing arrangements, incident reporting, business continuity and security policies
Advise the CEO and board on regulatory risk, and make sure product and commercial decisions are aligned with FCA expectations
After authorisation, continue as MLRO and Head of Compliance: run the monthly safeguarding return, the annual safeguarding audit, compliance monitoring and suspicious activity reporting
Train staff and embed a compliance culture that suits a fast-moving technology business
A proven track record of taking a payments or e-money firm through FCA authorisation, ideally as an Authorised Payment Institution, and a clear account of what you personally wrote and led
Hands-on experience of safeguarding for payments firms, ideally under the new CASS 15 regime
Previous experience as MLRO or Head of Compliance in a regulated payments, e-money or fintech business
Strong working knowledge of the Payment Services Regulations 2017, the Money Laundering Regulations and FCA expectations for payment institutions
A relevant compliance or financial crime qualification, for example from the ICA, CISI or ACAMS, is desirable
Excellent communication skills, with the ability to explain regulation clearly to a founder and board with a strong technology background
Comfortable building frameworks from scratch in a small team, and working one day a week on a long-term basis
Based in or able to travel to London, with availability to start promptly
A long-term fractional appointment: lead the application, then stay on as Head of Compliance & MLRO
Direct access to the CEO and board, and real influence over how the compliance function is built
The chance to write an application from the ground up and then run the regulated business you helped…