Authorised and registered firms should have heads of compliance and money laundering reporting officers (MLROs) who are suitably competent and capable of effectively performing the roles. Firms should carefully consider how individuals can demonstrate this ahead of seeking regulatory approval.

Heads of compliance and MLROs are important roles within financial services firms and many firms are required to have an FCA-approved senior management function (SMF) holder eg, SMF16 and SMF17. They will need necessary skills and knowledge, from training and experience, to be effective. The level of those skills and knowledge should be in line with the size of the firm and its risk of harm.

The following, based on our experience of approved applications, should help firms decide if an individual candidate is suitable.


Most successful applicants have:

We do not endorse or recommend any courses or training providers, or prescribe the form training should take, whether that’s classroom-based courses, e-learning or course books/materials. However, we have found courses with an examination or assessment are better in demonstrating that an individual has gained relevant knowledge.


While relevant experience to demonstrate competency and capability may come in many forms, we note that:

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