Annex 1 Firm Compliance Recruitment

Annex 1 firms — the non-bank lenders, leasing companies, money brokers and safe-custody providers registered with the FCA for anti-money-laundering supervision — are under more regulatory scrutiny than at any point in their history. Following a high-profile lender collapse in 2026 and a marked step-up in FCA attention on the sector, these firms are expected to demonstrate genuinely robust AML frameworks and adequately-resourced compliance functions. We help them do exactly that, by placing the MLROs, compliance officers, financial-crime specialists and finance leaders the current environment demands. If you run an Annex 1 firm and need to strengthen your compliance resource, this is what we do. For the background on the regime itself, see our complete guide to Annex 1 firms.

Why Annex 1 firms are recruiting now

The regulatory environment has changed. The FCA has signalled clearly that it is scrutinising the Annex 1 population — concerned that some firms rely too heavily on parent-company arrangements or on generic compliance procedures not suited to their business, and alert to the risk of these firms being used to facilitate financial crime. For many firms the issue isn’t intent but capacity: a compliance function built for a smaller, quieter business that hasn’t kept pace as the firm grew. Closing that gap means bringing in people with the seniority and specific expertise to build or upgrade an AML framework and to hold the key roles credibly. That is where demand has risen, and where we help.

The roles we recruit for Annex 1 firms

Money Laundering Reporting Officer (MLRO)

The central appointment. Every Annex 1 firm needs a Money Laundering Reporting Officer with the seniority, time and expertise its risk profile demands — not a nominal role-holder. We place experienced MLROs who can own the AML framework, handle suspicious-activity reporting, and stand up to regulatory scrutiny. For firms moving towards the senior-manager (SMF17) model as they grow or seek authorisation, we recruit accordingly.

Compliance officers and heads of compliance

Beyond the MLRO, firms need compliance resource to operate the framework day to day — and, as they scale, a head of compliance or chief compliance officer to lead it. We place compliance professionals who understand the Annex 1 regime and can build proportionate, working controls rather than paper ones.

Financial-crime and AML specialists

Building and running effective customer due diligence, monitoring and screening processes takes specialist skill. We recruit financial-crime and AML specialists who can design and operate these controls to the standard the regulator now expects.

Finance leaders who understand the regime

Many Annex 1 firms — particularly lenders — also need finance leadership that understands the regulatory environment they operate in. We place CFOs and finance directors who can partner with the compliance function and give the board a clear-eyed view of both the numbers and the regulatory risk.

Permanent, interim or fractional

The right resourcing model depends on the firm’s size and urgency. A larger Annex 1 firm may need a permanent, full-time MLRO and compliance team. A smaller one — or one that needs to close a gap quickly ahead of regulatory scrutiny — is often better served by an interim or fractional appointment: a genuinely experienced compliance leader for the days a week the firm actually needs, at a fraction of the cost of a full-time hire. We recruit across all three models, and part of the value we add is advising which fits a given firm’s situation rather than simply filling the brief as stated. For firms under time pressure because the regulator is already asking questions, an experienced interim can be in place quickly.

The Annex 1 firms we work with

‘Annex 1’ covers a broad range of businesses, and the compliance resource each needs varies with its activity and scale. We work across the full spread of the population. Non-bank and specialist lenders — including bridging and development lenders — are among the most affected by the current scrutiny, given the regulator’s specific interest in lending conducted through complex structures; these firms need genuinely robust AML frameworks and credible MLROs. Financial leasing companies, money brokers and safe-custody providers each carry their own money-laundering risk profile and need controls tailored to it rather than lifted from a template. And firms dealing in high-value goods or otherwise caught by the Money Laundering Regulations need proportionate frameworks that reflect how their business actually operates. Whatever the activity, the common need is the same: compliance resource matched to the firm’s real risk, not a nominal appointment.

How we work

We understand the brief and the risk

We start by understanding the firm — its activities, its scale, where it sits with the regulator, and what the compliance function genuinely needs. That lets us advise on the right role and the right level, including whether a permanent, interim or fractional appointment fits best, rather than simply taking an order.

We draw on a specialist network

Because we focus on regulated-firm finance and compliance recruitment, we know the people who do these roles well — experienced MLROs, compliance leaders and financial-crime specialists who understand the Annex 1 environment. That specialist network is what lets us present genuinely suitable candidates rather than a generic longlist.

We move at the pace the situation needs

Where a firm is under time pressure — because the regulator is already asking questions, or a key role has fallen vacant — we can move quickly, including placing an experienced interim to hold the position while a permanent search runs. Getting the right person in credibly and promptly is often the single most reassuring step a firm can take.

What makes a strong compliance hire for an Annex 1 firm

Not every compliance CV is the right fit for an Annex 1 firm, and part of our job is knowing the difference. The strongest hires combine genuine AML expertise with the practical judgement to build controls that are proportionate to the business rather than either box-ticking or gold-plated. They can take an honest view of the firm’s real money-laundering risk and design a framework that matches it — tailored to the firm’s activities, not lifted from a template that impresses on paper but doesn’t reflect how the business works. They have the seniority and independence to challenge the executive where needed, and the credibility to represent the firm to the regulator with confidence. For a lender in particular, they understand the specific risks that come with the firm’s structures and products, and can build customer due diligence and monitoring that genuinely tests source of funds and the substance of a transaction. And they bring the calm that comes from having done it before — which matters most when a firm is responding to regulatory scrutiny and needs to demonstrate control quickly. Screening for that combination, rather than for a plausible CV, is exactly what a specialist recruiter adds over a generalist one.

Why FD Capital

We specialise in senior finance and compliance recruitment for FCA-touching firms, with a deep bench across regulated-firm compliance — MLROs, compliance officers, financial-crime specialists and regulated-firm CFOs. Every search is led personally by Adrian Lawrence FCA, a chartered accountant and former listed-company finance director, so you deal directly with someone who understands both the finance and the regulatory dimensions of these roles. We know the Annex 1 environment, we know the people who do these jobs well, and we can move quickly when the situation demands it. If your firm needs to strengthen its compliance resource in response to the changed regulatory environment, we’ll help you find the right person.

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