Hiring a Chief Compliance Officer and MLRO for a Payments Firm or EMI: What Regulators Expect

The legal duties, FCA expectations and 2026 safeguarding rules that shape compliance and MLRO hiring at payment institutions and EMIs, and who to hire first.

Sam Wellalage, Founder
October 30, 2026
10 min read

A UK payments firm or e-money institution (EMI) must name a compliance officer, a nominated officer for suspicious activity reporting (the MLRO), and an individual who monitors and manages its anti-money laundering controls. Its directors and managers must be of good repute with the knowledge and experience to run a payments business. Since May 2026 it must also give one director or senior manager responsibility for safeguarding oversight. The FCA tests these people at authorisation, often in a fit and proper interview, and keeps testing them through supervision.

This guide is for founders, CEOs and boards of payment institutions and EMIs hiring a Chief Compliance Officer, an MLRO, or one person to do both.

Does a payments firm or EMI legally need a compliance officer and an MLRO?

Yes. The requirements sit in three places.

  • The Money Laundering Regulations 2017. Regulation 21 requires a firm, where appropriate to its size and nature, to appoint a board member or senior manager as the officer responsible for its compliance with the regulations. It must also appoint a nominated officer to receive internal suspicion reports. That is the role the industry calls the MLRO. The firm must tell its supervisor who holds each role within 14 days of the appointment.
  • A payments-specific duty. Regulation 21(7) goes further for e-money issuers and payment service providers. They must appoint an individual to monitor and manage compliance with their AML policies, identify higher-risk situations, keep records of the risk assessment, embed controls into new products and onboarding, and report to senior management at least annually.
  • The conditions for authorisation. The Payment Services Regulations 2017 and the Electronic Money Regulations 2011 require directors and the people responsible for managing the business to be of good repute and to have appropriate knowledge and experience.

What payments firms do not have, today, is the Senior Managers and Certification Regime (SM&CR). Payment institutions and EMIs are authorised under the PSRs and EMRs rather than FSMA, so there are no SMF16 or SMF17 approvals to apply for. That may change. HM Treasury's Modernising Payment Services Regulation consultation, open from 14 July to 6 October 2026, asked whether enhanced accountability for senior managers of payments and e-money institutions would help manage financial crime risk. Hire as though personal accountability is coming, because the direction of travel points that way.

What is the difference between a Chief Compliance Officer and an MLRO at an EMI?

The MLRO owns financial crime. The Chief Compliance Officer owns everything else the regulator can hold the firm to. In a small firm they are often the same person. In a scaling one they rarely should be.

The MLRO typically covers:

  • the business-wide money laundering and terrorist financing risk assessment
  • customer due diligence and enhanced due diligence standards
  • transaction monitoring and sanctions screening
  • deciding whether internal reports become suspicious activity reports to the National Crime Agency
  • financial crime training and annual reporting to the board

The Chief Compliance Officer typically covers:

  • safeguarding compliance, which has become a discipline of its own (see below)
  • the Consumer Duty, complaints and fair treatment of customers
  • oversight of agents, distributors and outsourced providers
  • regulatory reporting, change management and the relationship with the FCA
  • compliance monitoring across conduct of business rules

The overlap is where problems start. Agent networks, embedded finance partners and cross-border corridors are both conduct and financial crime risks. Whoever you hire, write down which of them owns each one.

What does the FCA expect from an MLRO at a payments firm?

The FCA has been unusually specific. In its guidance video for payments and digital asset applicants, its authorisations team notes that the latest National Risk Assessment found payments and digital assets firms particularly susceptible to money laundering. It then sets out what it looks for in an MLRO.

  • No formal qualification is required. The FCA says it has seen better applications where the MLRO has completed detailed external AML training. Without that, it expects a very good working knowledge of the UK Money Laundering Regulations.
  • Knowledge is tested in interview. The FCA often uses a fitness and propriety interview. It gives three example questions: how money laundering and terrorist financing might occur in your firm, how your products could be used to launder money, and how your controls work to prevent it.
  • The MLRO must know the business model. The FCA expects the MLRO to explain every product, service and feature, and to speak confidently about inherent risk across customers, geographies, transaction flows, delivery channels and onboarding.
  • Four further tests. Independence (for example, is the MLRO also responsible for bringing in business?), sufficient time, horizon scanning for new threats and rule changes, and training for both the MLRO and staff.

The practical point for hiring: a candidate with a strong CV from a bank who cannot explain your payment flows, your corridors and your onboarding journey in plain terms will struggle in that interview. Product fluency matters as much as regulatory knowledge.

How do the 2026 safeguarding rules change the compliance hire?

They raise the bar significantly. The FCA's PS25/12, published in August 2025, introduced new safeguarding rules for payments and e-money firms that came into force on 7 May 2026. Under them, firms must:

  • perform safeguarding reconciliations at least once each business day
  • maintain a resolution pack so customer funds can be returned quickly if the firm fails
  • submit a new monthly safeguarding return to the FCA
  • arrange an annual safeguarding audit by a qualified auditor, unless relevant funds have not exceeded £100,000 at any time in the previous 53 weeks
  • carry out due diligence on third parties that hold or manage relevant funds

The governance rule is the one that affects hiring. New CASS 15.2.4R requires a firm to allocate to a single director or senior manager of sufficient skill and authority responsibility for oversight of its operational compliance with the safeguarding regime, and for reporting on it to the governing body.

That person is often the CFO or COO, because safeguarding sits close to treasury and finance operations. Compliance still needs someone who understands reconciliations, relevant funds and insurance or guarantee arrangements well enough to test them. If your compliance lead has only ever worked in AML, this is a gap to close, either in the hire or in the team around them.

What else is the FCA focusing on for payments firms?

The FCA's February 2025 letter to payments firm CEOs is the clearest statement of supervisory priorities. It names weaknesses in governance, oversight and leadership as a root cause of many of the regulatory issues the FCA sees in the sector. It sets expectations that bear directly on the compliance hire:

  • Independent challenge. Governance should provide effective and independent challenge to business decisions, with non-executive directors playing a crucial role.
  • Agents and distributors. Firms should take a robust and holistic approach to monitoring them.
  • Outsourcing. Outsourced functions must work as intended and stay compliant.
  • Location. A UK-authorised PI or EMI must have its head office in the UK, and directors and senior managers making central and day-to-day decisions should be based there.
  • Consumer Duty and fraud. The letter expects full Consumer Duty implementation, highlights clarity of foreign exchange pricing, and points firms to the authorised push payment (APP) fraud reimbursement requirements.

Can one person be both the compliance officer and the MLRO?

Nothing in regulation 21 prevents one person from holding the compliance officer, nominated officer and regulation 21(7) roles, and many early-stage EMIs combine them. The question is capacity and independence, which are exactly the tests the FCA describes.

Combining them tends to work when the firm has a single product, a limited number of corridors, no agent network and modest alert volumes. It stops working when the MLRO spends most of the week on suspicious activity decisions and has no time left for safeguarding, Consumer Duty or regulatory change. At that point the firm needs a dedicated MLRO reporting into a Chief Compliance Officer, or two peers reporting to the CEO and board.

Should the MLRO be in-house, fractional or outsourced?

Fractional and consultant MLROs are common in pre-authorisation applications, and for a firm with no customers yet that can be reasonable. Be careful about relying on it after launch.

Regulation 21(3) requires the nominated officer to be "an individual in the relevant person's firm". The FCA asks whether the MLRO has sufficient time. And the authorisation conditions turn on the competence of the people responsible for managing the business. A part-time MLRO covering several firms, with no feel for your daily flows, is hard to defend on all three counts once you are processing live payments.

A sensible pattern is a fractional MLRO to build the framework and support the application, with a permanent MLRO hired in time to own the controls before launch. Plan the search early. Experienced payments MLROs are in demand, and a good one may have a notice period of several months.

What applies to EMIs and payment institutions in the EU?

The EU's new Anti-Money Laundering Regulation, Regulation (EU) 2024/1624, applies from 10 July 2027 and formalises two roles under Article 11:

  • A compliance manager: a member of the management body in its management function, responsible for ensuring compliance and for making sure the compliance functions are adequately resourced.
  • A compliance officer: appointed by the management body with sufficiently high hierarchical standing, responsible for day-to-day AML/CFT policies and controls, including targeted financial sanctions, and for reporting suspicious transactions to the financial intelligence unit.

The regulation also requires firms to protect the compliance officer from retaliation and from decisions being unduly influenced by commercial interests, to notify the supervisor of a removal, and to let the compliance officer report directly to the management body. For groups running an EMI in both the UK and the EU, that means two clearly owned sets of roles, not one person stretched across both.

What profile should you hire, and in what order?

Hire the MLRO first if you are pre-authorisation. The FCA has published detailed expectations for that role and tests the candidate directly, so a weak appointment puts the whole application at risk. Add a Chief Compliance Officer when you have a second product line, an agent or partner network, material safeguarded balances, or a second jurisdiction.

Signals of a strong payments MLRO or CCO:

  • has written a business-wide risk assessment for a payments or e-money firm, not only applied someone else's
  • can explain how your specific products could be abused, before you prompt them
  • has run, or closely supervised, transaction monitoring tuning and alert backlogs
  • has dealt directly with the FCA, through authorisation, a skilled person review or supervisory visits
  • understands safeguarding mechanics, not only the rule text
  • has said no to a commercial team and can tell you how it ended

Warning signs:

  • a career entirely inside large bank control functions with no experience of building from scratch
  • a candidate who expects to also own sales, partnerships or revenue targets
  • vague answers when asked how they would fund and staff their own function
  • multiple concurrent fractional roles they intend to keep after joining you

Use the FCA's own questions in your interview process. If a candidate cannot answer them well for your business after a proper briefing, the regulator will reach the same conclusion.

How should you structure and pay the role?

Structure first. The compliance lead should report to the CEO with direct access to the board or risk committee and to the non-executive directors. That reflects both the FCA's emphasis on independent challenge and the EU's direct reporting requirement. Give them a budget they control for monitoring tools and headcount. A compliance officer who has to ask the commercial team for permission to hire an analyst is not independent in any meaningful sense.

On pay, the market for experienced payments MLROs and compliance heads is competitive, especially for people who have already taken a firm through authorisation. Avoid tying a meaningful share of their variable pay to revenue or onboarding volumes, which undermines the independence the FCA tests for. For current ranges, see our salary guide.

Where to start

List every control role your regime requires: compliance officer, nominated officer, the regulation 21(7) individual, and the safeguarding oversight owner. Name who holds each, where they sit, and whether they would pass an FCA interview about your business today. Then hire into the gaps.

Spearpoint Search runs retained searches for fintech and payments leadership, including compliance and MLRO appointments, and will tell you plainly if the role as scoped will not survive regulatory scrutiny or attract the right people. If you are hiring, see how we work with clients. If you are a compliance leader weighing a move, start here. For Sam's deeper take on why boards sometimes hire for cover rather than capability, read The Hire Isn't the Point. The Cover Is. in Talent Before Capital.

This article is general information, not legal or regulatory advice. Requirements vary by firm, activity and jurisdiction, and regulators update their rules and guidance. Take advice from qualified counsel before applying for authorisation or making control function appointments.

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Frequently asked questions

Does a payments firm need an MLRO?

Yes. Regulation 21 of the Money Laundering Regulations 2017 requires every UK payment institution and EMI to appoint a nominated officer to receive internal suspicion reports, which is the role known as the MLRO. Firms must also, where appropriate to their size, appoint a board member or senior manager responsible for AML compliance, and tell the FCA who holds both roles within 14 days of appointment.

Does SM&CR apply to payment institutions and EMIs?

Not currently. Payment institutions and EMIs are authorised under the Payment Services Regulations and Electronic Money Regulations rather than FSMA, so there are no SMF16 or SMF17 approvals. HM Treasury's 2026 consultation on modernising payments regulation asked whether enhanced senior manager accountability should apply to the sector, particularly for financial crime, so firms should expect clearer individual accountability over time.

Can the compliance officer and MLRO be the same person at an EMI?

Yes. Nothing in regulation 21 prevents one person holding both roles, and it is common in early-stage firms. The FCA will look at whether that person has enough time and sufficient independence, for example whether they also have commercial responsibilities. As products, corridors, agents and alert volumes grow, most firms separate the roles or build a team beneath the combined lead.

What qualifications does the FCA expect an MLRO to have?

The FCA says it does not expect formal qualifications, but it has seen better applications where the MLRO has completed detailed external AML training. Without that, it expects a strong working knowledge of the UK Money Laundering Regulations. It often tests this in a fit and proper interview, asking how money laundering could occur in the firm and how its controls prevent it.

Who is responsible for safeguarding under the new FCA rules?

Under CASS 15.2.4R, which came into force on 7 May 2026, a payments or e-money firm must allocate to a single director or senior manager of sufficient skill and authority responsibility for oversight of its operational compliance with the safeguarding regime and for reporting to its governing body. This is often the CFO or COO, with compliance testing the arrangements.

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