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Fractional & Interim MLRO Support for Fintech, PSPs, EMIs and Crypto

Senior financial crime leadership, governance and escalation support for firms that need MLRO-level judgement before, during or alongside a permanent hire.

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Fractional, interim, deputy MLRO, nominated officer and advisory support models
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Built around your operating model, customers, products, rails and financial crime risks
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Support across governance, escalation, controls, MI and FCA follow-up
Request a Triage CallDiscuss MLRO Support
Led by a former SMF17 MLRO • Not legal advice • No approval guarantees

Support is tailored to your firm’s permissions, operating model, governance structure and financial crime risks.

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MLRO cover without a full time hire


For firms that need practical MLRO input, financial crime governance and escalation support before appointing a permanent MLRO, while scaling, or during FCA application and follow up.
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FCA applicants needing a credible MLRO and financial crime governance model
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Recently authorised firms formalising oversight, reporting and escalation
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Interim or fractional cover before a permanent MLRO is appointed
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Scaling fintech, payments, EMI and crypto firms where the MLRO function is stretched
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Support with SAR, sanctions, high risk customer and transaction monitoring escalations
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Firms responding to FCA questions about MLRO capability, resourcing, controls or governance
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What you get


Business-wide risk assessment, AML/KYC policies, governance, controls and FCA follow-up support — built around your actual products, customers, flows and risks, not generic templates.
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A clear AML and financial crime framework for the FCA application
A BWRA that explains the firm’s real financial crime risks
Governance and MLRO oversight that can be explained and evidenced
A stronger basis for answering FCA follow-up questions
Practical day-one controls, not template documentation
Policies and controls linked to your products, customers, flows and risk profile
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Deliverables

How we work

Business-wide risk assessment
AML/KYC policy and procedures
Customer risk assessment methodology
CDD, EDD and onboarding standards
Sanctions and screening controls
Transaction monitoring and escalation framework
Governance, MLRO reporting and oversight model
Application narrative and FCA follow-up support
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  • Review. We review the business model, draft application materials and existing AML documentation.
  • Build. We build or strengthen the BWRA, policies, controls and governance evidence.
  • Prepare. We help prepare for FCA questions, interviews and follow-up requests.

Where this fits

FAQs

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Fixed-scope sprint or ongoing advisory support
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Clear deliverables and review points
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Works alongside your legal, licensing or compliance advisers
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No FCA approval guarantees
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Not a legal advice
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Not end-to-end application management unless agreed
Can you handle end-to-end licensing?

We focus on the AML and financial crime parts of the application. If full licensing support is needed, we can work alongside your advisers or coordinate with trusted partners.

What makes you different?

We are a small, senior-led consultancy focused on practical AML and financial crime work, not template packs or paper compliance. You get clear ownership, regulator-aware judgement and controls designed around how your business actually operates.

Can you work with our existing lawyers or licensing advisers?

Yes. We work alongside existing lawyers, licensing advisers or internal teams, focusing specifically on the AML, financial crime, governance and evidence parts of the FCA application.

Can you help if we already submitted and received FCA questions?

Yes. We can review the FCA’s questions against your submitted AML/financial crime materials, identify what is missing or unclear, and help prepare evidence-based responses that address the regulator’s concerns directly.

Need an AML part for your FCA application?

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