From AML to Fraud Prevention: Building a Financial Crime Team That Satisfies the FCA

Most regulated firms think about financial crime hiring as filling individual roles. The smarter question is whether the team, as a whole, covers the ground the FCA expects it to cover.

That distinction matters more than it might seem. A strong MLRO who is expert in AML but unfamiliar with sanctions screening leaves a gap. An experienced fraud analyst who has never worked on transaction monitoring calibration leaves a different gap. And a financial crime director who is brilliant at writing policies but has not led a suspicious activity investigation in years leaves yet another.

The FCA does not audit job descriptions. It audits outcomes.

What the FCA Is Actually Looking For

The FCA’s expectations around financial crime have crystallised considerably over the past three years. The Financial Crime Guide, the Dear CEO letters addressed to specific sectors, and the outcomes of a growing number of enforcement actions all point in a consistent direction.

The regulator wants to see that firms understand their specific risk exposure — not just that they have completed a generic risk assessment. It wants evidence that the people responsible for financial crime controls have genuine expertise relevant to the firm’s actual business model. And it wants to see that financial crime functions are resourced in proportion to the risks the firm is running.

That last point is significant for hiring. A payment institution processing high volumes of international transfers needs a different financial crime team than a small wealth manager serving domestic clients. Both need competent people. But competent at what, specifically, varies considerably.

The Three Disciplines That Often Get Conflated

When firms come to us with financial crime hiring needs, one of the first things we try to establish is whether they are thinking clearly about which part of the financial crime landscape they actually need to cover.

AML and CTF is the traditional core — transaction monitoring, SAR filing, customer due diligence, enhanced due diligence for higher-risk relationships. This is the area most financial crime professionals enter through, and where supply is least thin.

Sanctions compliance is a distinct specialism, and one that has moved up the priority list sharply since 2022. Firms with exposure to sanctioned jurisdictions, complex correspondent banking relationships, or significant cross-border flows need people who understand OFSI, OFAC, and the UN regime — and who can work with screening systems rather than simply relying on them.

Fraud and financial crime investigation sits in a different place again. This covers both first-party and third-party fraud, often requires close liaison with law enforcement, and calls for a different investigative mindset than the compliance-oriented work of AML or sanctions.

Many financial crime professionals have depth in one of these areas and reasonable familiarity with the others. Genuinely strong candidates across all three are rare, senior, and expensive. Firms that understand this upfront make better decisions about team structure — whether that means building specialist capability in-house, supplementing with interim resource, or prioritising their hiring sequence differently.

Thinking About the Team, Not Just the Role

The most effective financial crime hiring conversations we have are the ones where the client is thinking about team design rather than just vacancy filling. Where does the current team have depth? Where does it have gaps? Is the MLRO spending time on activity that a more junior hire could absorb? Is there specialist knowledge that currently sits in one person and creates a key-person dependency?

These are not always questions that come naturally in the middle of a busy hiring process. But they are the questions that lead to better outcomes — both for the firm’s regulatory standing and for the quality of the team it builds over time.