Fractional MLRO / Nominated Officer - Annex 1 Registration
Capitex · London
Job description
About the role
A London-based private credit fund is appointing an experienced financial crime professional as nominated officer for two lending entities registering with the Financial Conduct Authority as Annex 1 financial institutions. This is a genuine fractional appointment of two to three days per month, with flexible scheduling, remote work and occasional attendance in Central London. The business lends to UK corporates, with about ten people, roughly three deals a year of £10m to £150m, mostly junior and mezzanine debt; due diligence is prepared in-house by the deal team.
Key responsibilities
- Act as nominated officer under Regulation 21(3) of the Money Laundering Regulations 2017 for both entities, named on each application and subject to the FCA's fitness and propriety assessment
- Review, challenge and sign off customer due diligence files covering group structure, directors, ultimate beneficial owners and controlling parties
- Validate risk ratings, decide where enhanced due diligence is needed, 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, and oversee sanctions screening and OFSI reporting
- Contribute to the business-wide risk assessment, policies and controls, working with the firm's external compliance consultancy
- Provide periodic management information and board reporting on financial crime matters
Required profile
- Demonstrable experience as an MLRO or nominated officer, sufficient 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 such as private credit, specialty finance, asset-based lending or corporate and wholesale banking; retail-only backgrounds are not suited
- Sound judgement on corporate structures, ultimate beneficial ownership and source of funds in complex-ownership lending
- Right to work in the UK
What we offer
- Contract engagement through Capitex, hourly and all-inclusive, billed against approved timesheets with no minimum term
- Flexible scheduling of two to three days per month, with concurrent engagements accommodated subject to a written conflicts declaration
- Pre-engagement screening: identity, right to work, employment references, basic DBS and credit check
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Published 1 day ago
Expires 1 month from now
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Capitex
London
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