Part-time MLRO and Head of Compliance support for growing FCA-regulated firms, the same regulatory cover a full-time appointment would give you, scaled to what your firm actually needs right now.
Lots of smaller firms don’t need a full-time Head of Compliance and MLRO the day they’re authorised, and for many, that day never quite arrives. However, the regulatory requirements remain the same. Within the FCA’s Senior Managers and Certification Regime (SMCR), there’s a need for a role holder for SMF16 (Compliance Oversight) and SMF17 (MLRO, financial crime). Even for FCA-registered firms that sit outside SMCR, there’s still a need to ensure sufficient regulatory compliance and financial crime (MLRO) focus.
That’s the gap fractional Head of Compliance and MLRO support is built for: an experienced compliance professional who takes on the SMF17, and where needed the SMF16, responsibilities on a part-time, flexible basis, sized to your firm’s stage, risk profile and budget rather than a full-time salaried hire you don’t yet need.
Clarionet Consulting provides outsourced, interim and part-time MLRO and Head of Compliance support to fintechs, payment and e-money firms, consumer credit lenders and other smaller financial services businesses across the UK, built and led by a former bank Head of Compliance and MLRO.
Clarionet Consulting is founded and led by Gary Watson, who spent nine years as Head of Compliance and MLRO for a UK bank, holding SMF16 and SMF17 concurrently for eight of those years, and led that bank through subsidiarisation to secure its own UK banking licence. Before that, he spent five years in financial crime advisory at Deloitte, including a secondment to the FSA’s 2011 thematic review of banks’ management of high money-laundering-risk situations.
Today, alongside Clarionet Consulting engagements, Gary is currently acting as fractional MLRO and Compliance Lead for an early-stage fintech, building its complete financial crime and conduct compliance policy suite from the ground up ahead of FCA authorisation, which is the same kind of hands-on, build-it-properly work a fractional engagement with Clarionet involves.
“A customer-centric compliance culture isn’t a regulatory burden: it’s a commercial advantage.”
Every engagement is scoped to your size, sector and risk profile, as a monthly retainer, a fixed-fee project, or day-rate advisory, whichever fits how your firm actually operates. There’s no assumption that a fractional MLRO means a bare-minimum service: the obligations are the same ones a full-time appointment would carry, delivered on a schedule that matches what your firm needs rather than what a full-time role would cost.
Most FCA-regulated firms within scope of the Money Laundering Regulations must appoint a nominated officer to oversee AML compliance and submit SARs to the NCA. If you’re not sure whether that applies to you, that’s the first thing worth checking.
Yes, many smaller firms combine SMF16 and SMF17 in a single fractional appointment, with independent Board access to perform both functions objectively. As a firm grows, there’s often a point where it makes sense to split them; we can advise on when that point is right for you.
It depends on scope and the level of cover your risk profile requires. Fixed-fee, day-rate and monthly retainer options are all available, so get in touch for a free initial consultation and an indicative proposal.
A free, no-obligation initial consultation to work out what level of fractional MLRO or compliance support actually fits your firm.