Fractional MLRO​/Nominated Officer – Annex Registration

• Act as nominated officer under Regulation 21(3) of the Money Laundering Regulations 2017 for both registering entities, named on each application and subject to the FCA's assessment of fitness and propriety via the MLR Individual form
• Review, challenge and sign off customer due diligence files prepared by the deal team, covering group structure, directors, ultimate beneficial owners and controlling parties
• Validate risk ratings, determine where enhanced due diligence is required, and approve escalations, overrides and red flags in line with policy
• Own the annual KYC and AML refresh, including change of ownership and control triggers under facility agreements
• Take suspicious activity reporting decisions and submit to the NCA where required
• Oversee sanctions screening and OFSI reporting obligations
• Contribute to the business-wide risk assessment, policies and controls, working alongside the firm's external compliance consultancy through the registration process
• Provide periodic management information and board reporting on financial crime matters
• Report to the board
• Overall responsibility for the firm's compliance under Regulation 21(1)(a) remains with an internal senior manager, and an internal deputy nominated officer is in place

• Demonstrable experience as an MLRO or nominated officer, of sufficient standing to satisfy the FCA's fitness and propriety assessment
• Direct experience of Annex 1 registration under the Money Laundering Regulations 2017, ideally having taken a firm through the application process
• Lending background - private credit, specialty finance, asset-based lending, corporate or wholesale banking
• Retail-only backgrounds are not suited to this mandate
• Sound judgement on corporate structures, ultimate beneficial ownership and source of funds in a complex-ownership lending context
• Right to work in the UK
• Experience acting in a fractional, portfolio or non-executive compliance capacity across more than one firm (desirable)
• Familiarity with private credit fund structures and institutional or sovereign wealth backing (desirable)

Demonstrates expertise as a Money Laundering Reporting Officer (MLRO) with a strong understanding of the Money Laundering Regulations 2017, including Annex 1 registration and compliance responsibilities. Capable of conducting thorough customer due diligence, risk assessments, and suspicious activity reporting while providing strategic oversight and management information to the board.

• Money Laundering Reporting Officer (MLRO)
• Annex 1 Registration
• Customer Due Diligence (CDD)
• Risk Assessment
• Suspicious Activity Reporting

• Regulation 21(3) Compliance
• Enhanced Due Diligence (EDD)
• Financial Crime Reporting
• Corporate Structures Analysis
• Ultimate Beneficial Ownership (UBO) Assessment

• Sound Judgement
• Decision-Making

• Private Credit
• Specialty Finance
• Asset-Based Lending
• Corporate Banking
• Wholesale Banking

• Sanctions Screening Tools
• Compliance Management Systems