Payments & E-Money Compliance Recruitment — Heads of Compliance, MLROs and safeguarding leaders for payment institutions, EMIs and embedded payments firms

Payments and E-Money Compliance Recruitment

Payments has become one of the most demanding environments in UK financial services compliance. Authorised payment institutions and e-money institutions are operating under the FCA’s strengthened safeguarding regime, which took effect on 7 May 2026. Supervisors continue to focus on financial crime controls, fraud and the treatment of customers. And a steady flow of new firms, from embedded payments providers to open banking businesses, is going through authorisation and needs credible compliance leadership in place before the application goes in.

FD Capital recruits the compliance leaders payments firms depend on: Heads of Compliance, Money Laundering Reporting Officers, combined Head of Compliance and MLRO roles, Heads of Safeguarding, and the financial crime and fraud specialists beneath them. We work on interim, fractional and permanent bases for authorised payment institutions, e-money institutions, small EMIs, card programme managers, open banking providers, embedded payments and banking-as-a-service businesses, and payments firms that also hold FSMA permissions. Every payments compliance search is led personally by Adrian Lawrence FCA.

This page explains how compliance accountability works at a payments firm (which is not the same as at a bank or investment firm), why payments firms are hiring now, what a strong payments compliance candidate looks like, and how to time a hire around an authorisation application. If you need someone in the seat quickly, go to our contact page or call 020 3287 9501.

How compliance accountability works at a payments or e-money firm

Many founders assume their Head of Compliance and MLRO will be SMF16 and SMF17 approvals, as they would be at a bank or investment firm. For most payments businesses that is not the case, and understanding the difference shapes the hire.

Payment institutions and EMIs sit outside the Senior Managers and Certification Regime. Firms authorised solely under the Payment Services Regulations 2017 or the Electronic Money Regulations 2011 are not FSMA-authorised firms, so the SMF designations do not apply to them. Instead, the FCA assesses the fitness and propriety of the firm’s directors and of the individuals responsible for managing its payment services, at authorisation and when those individuals change.

The MLRO is still a statutory role. Payments and e-money firms are within the Money Laundering Regulations 2017 and must appoint a nominated officer to receive internal reports and submit suspicious activity reports. In practice the FCA scrutinises the MLRO closely at authorisation and expects the individual to be senior, experienced and adequately resourced. Our MLRO guide explains the role in full.

Where SM&CR does apply. If a payments business also holds FSMA permissions, for example to lend under consumer credit rules or to carry on investment business, the FSMA-authorised entity is an SM&CR firm and its compliance and MLRO holders will usually be SMF16 and SMF17. Groups combining an EMI with a lending or investment entity often need one individual who can operate credibly under both frameworks. Our guide to FCA authorisation versus registration sets out the different routes.

The practical point is that the FCA’s expectations of a payments Head of Compliance and MLRO are just as demanding as under SM&CR, even where the label differs. Candidates who have only worked in SM&CR firms sometimes underestimate how much of the regime is operational, and candidates who have only worked in payments sometimes lack governance depth. Finding people with both is the core of a good payments search.

Why payments firms are hiring compliance leadership now

1. The strengthened safeguarding regime

The FCA’s policy statement on safeguarding (PS25/12) introduced supplementary rules from 7 May 2026. They include daily safeguarding reconciliations on business days, a monthly safeguarding return to the FCA, an annual safeguarding audit by a qualified auditor (with a limited exemption for firms safeguarding small amounts), and a resolution pack that records where relevant funds are held and how they are managed. Firms that previously ran safeguarding as a finance process are now recruiting Heads of Safeguarding and strengthening compliance oversight of the controls. Our guide to safeguarding client funds covers the detail.

2. Financial crime and fraud

Payments firms move money quickly and at scale, which makes them attractive to criminals. The FCA’s supervision of the sector has repeatedly focused on customer due diligence, transaction monitoring, sanctions screening and the risk of firms being used for money mule activity. Firms are also living with the mandatory reimbursement regime for authorised push payment fraud introduced by the Payment Systems Regulator in October 2024, which has pushed fraud prevention up the board agenda. A payments MLRO now needs to understand fraud as well as money laundering. See our articles on sanctions screening for payment firms and financial crime recruitment.

3. Authorisation applications

Firms applying to become authorised payment institutions or e-money institutions must show the FCA a credible governance structure, including the people responsible for compliance and anti-money laundering. Applications that name an inexperienced or part-time MLRO without a convincing explanation tend to attract questions. Many of the mandates we handle begin months before submission, when a founder realises the compliance hire is the weakest part of the application.

4. Agents, distributors and partners

Embedded payments and banking-as-a-service models mean that many payments firms operate through agents, distributors, programme managers or platform partners. Oversight of those relationships is a recurring supervisory theme, and a compliance leader who has built a partner oversight framework is particularly valuable.

5. Vacancies and turnover

Experienced payments MLROs are in short supply, and turnover is high. When an MLRO resigns, the firm must keep suspicious activity reporting running from the first day. For FSMA-authorised entities, our page on SMF16 and SMF17 temporary cover under the 12-week rule explains the cover options. For payments-only firms, the same urgency applies, along with the obligation to notify the FCA of changes to the individuals responsible for management.

The payments compliance roles we recruit

• Head of Compliance / Chief Compliance Officer: owner of the compliance framework, compliance monitoring and the firm’s relationship with the FCA.
• Money Laundering Reporting Officer: the nominated officer, responsible for the firm-wide risk assessment, suspicious activity reporting and the financial crime framework.
• Combined Head of Compliance and MLRO: the most common shape at early-stage and mid-sized payments firms.
• Deputy MLRO: expected at most firms with meaningful volumes, so that reporting continues when the MLRO is unavailable.
• Head of Safeguarding: owner of safeguarding reconciliations, the monthly return, audit readiness and the resolution pack, often sitting between finance and compliance.
• Head of Financial Crime / Fraud: transaction monitoring, sanctions, fraud prevention and authorised push payment reimbursement.
• Compliance Monitoring Manager: testing of controls across onboarding, payments operations, complaints and partner oversight.
• Partner and Agent Oversight Manager: due diligence and ongoing monitoring of agents, distributors and embedded partners.

Payments firms also need strong finance leadership. Our payments firm CFO recruitment page covers CFOs, Finance Directors and the finance side of safeguarding, and our MLRO recruitment and compliance recruitment pages cover the wider market.

What a strong payments compliance candidate looks like

Fluency in the payments framework. The best candidates know the Payment Services Regulations, the Electronic Money Regulations and the FCA’s approach to applying them, including conduct of business requirements, complaints handling and strong customer authentication. Our guides to the Payment Services Regulations and e-money institutions give a sense of the ground they should cover comfortably.

Operational financial crime experience. A payments MLRO should be able to explain how they have tuned transaction monitoring to reduce false positives without missing genuine risk, how they have handled defence against money laundering requests under time pressure, and how they have dealt with a surge in mule activity. Experience of card scheme requirements and correspondent or sponsor bank due diligence is a strong advantage.

Safeguarding literacy. Even where a separate Head of Safeguarding exists, the compliance leader must understand segregation, reconciliation, the insurance and guarantee methods, and what an auditor will test. Candidates who have been through a safeguarding audit or remediation are especially valuable under the new regime.

Comfort with technology and data. Payments compliance runs on systems. Strong candidates can work with engineers and product teams, specify controls that can actually be built, and read the MI that tells them whether those controls work.

Regulatory engagement. Prior experience of an authorisation, a variation of permission, a skilled person review or a supervisory visit tells you how a candidate performs under scrutiny. For firms with FSMA entities in the group, prior SMF approval is an advantage.

A builder’s mindset. Many payments firms are scaling fast. The best compliance leaders are those who can build a function from a small base, prioritise ruthlessly and earn the trust of founders and commercial teams.

Hiring compliance leadership for a payments authorisation

1. Decide the shape of the function. One combined Head of Compliance and MLRO, or two individuals? In-house from day one, or a fractional or interim leader while volumes build? The answer depends on your business model, expected volumes and risk appetite.
2. Recruit before you submit. The application describes your governance and the individuals responsible for compliance and anti-money laundering. Naming credible people strengthens the application; naming placeholders weakens it. The FCA authorisation timeline and the application process guide show where the hire fits.
3. Build the core documents with the hire, not before. Your firm-wide risk assessment, AML policies, safeguarding procedures and compliance monitoring plan should be owned by the person who will run them. An experienced interim can draft them and hand over to a permanent appointee.
4. Complete fitness and propriety checks early. References, criminal records checks and directorship history take time. Our fit and proper guide sets out what the FCA looks at.
5. Plan for growth. If you expect to add lending or other FSMA permissions later, hire someone who can step into an SMF16 or SMF17 role when the group needs it.

Interim, fractional or permanent?

Indicative pay and day rates

Pay depends on volumes, safeguarded balances, product complexity and whether the Head of Compliance and MLRO roles are combined. The ranges below are indicative of the London market for payments and e-money firms; our compliance salary guide and MLRO salary guide carry fuller benchmarks.

How FD Capital runs a payments compliance search

A precise brief. We start with your authorisation status, business model, volumes, safeguarding method, partner model and the current state of your financial crime framework. That tells us whether you need a builder, a remediator or someone to scale an existing function.

Speed on interim and fractional roles. For interim and fractional mandates we aim to put a shortlist in front of you within 48 to 72 hours, because good interim payments compliance professionals are rarely available for long.

Depth on permanent roles. For permanent appointments we take the time to test operational financial crime experience, safeguarding knowledge and regulatory track record, because getting the fit right matters more than raw speed.

Regulator-ready candidates. We check history on the FCA Financial Services Register, probe for reference issues early, and prepare candidates for the questions the FCA is likely to ask.

Live roles. Current payments and compliance vacancies are on our jobs board, and compliance professionals can register with us.

Frequently asked questions

Does our MLRO need to be an SMF17?

Only if the entity is FSMA-authorised and within SM&CR. A firm authorised solely as a payment institution or e-money institution still needs a nominated officer under the Money Laundering Regulations, and the FCA will assess that individual, but the SMF17 designation does not apply.

Can the Head of Compliance and MLRO be the same person?

Yes, and at smaller payments firms it is common. The FCA will expect the individual to have sufficient time, seniority and support, and you should have a deputy so that suspicious activity reporting continues during absences.

Can a fractional MLRO work for an EMI?

It can, for a small firm with modest volumes. As transaction volumes and safeguarded balances grow, the FCA will expect a more substantial commitment. Our article on outsourcing the MLRO function covers where the line usually falls.

Who should own safeguarding: finance or compliance?

Day-to-day reconciliation usually sits in finance or operations, while compliance provides oversight and challenge. Under the new regime many firms are appointing a dedicated Head of Safeguarding with clear reporting lines into both.

Should we hire from a bank or a payments firm?

For most payments firms, candidates from other payment institutions, EMIs or card programme managers are stronger, because they understand the operating model and the speed of the business. Bank candidates can work well at larger firms or those with lending entities.

Do you recruit compliance for other sectors?

Yes. We also recruit for consumer credit and BNPL lenders, cryptoasset firms, wealth managers and IFAs and insurers.