Location: UK, remote
Commitment: Fractional, around 1 day a week (10–20 hours a week during the application)
Day rate: £700–£1,000 per day
Start: As soon as possible
Role
SMF Capital is recruiting a fractional Money Laundering Reporting Officer for an online gambling business preparing its first Gambling Commission Remote Operating Licence application, covering remote casino and betting. The appointed MLRO will be named on the application and will build the anti-money laundering and counter-terrorist financing framework the business needs to be licensed and to operate from day one.
This is a ground-floor appointment. Licensing solicitors are already scoping the application, and the business wants an experienced gambling-sector MLRO alongside them to own the AML side of the submission, answer the regulator's questions with credibility, and then stay on as the firm's MLRO once it is licensed and trading.
The role suits an established MLRO who already works fractionally across more than one operator, or a senior AML professional from the gambling sector looking to build a portfolio of part-time appointments.
Act as the nominated MLRO on the Remote Operating Licence application and support the application through to grant, including responding to Gambling Commission queries.
Write the business's money laundering and terrorist financing risk assessment, covering customers, products, payment methods, geographies and delivery channels for remote casino and betting.
Draft the AML and CTF policies, controls and procedures required under the Money Laundering Regulations 2017, the Proceeds of Crime Act 2002 and the Commission's Licence Conditions and Codes of Practice.
Design customer due diligence and enhanced due diligence processes, including source of funds and source of wealth checks, affordability and safer gambling interactions where they overlap with AML.
Set out transaction monitoring rules and thresholds, and advise on the selection and configuration of KYC, screening and monitoring tools.
Establish the internal suspicious activity reporting process and act as the firm's nominated officer for SARs to the National Crime Agency.
Design and deliver AML training for directors, customer-facing staff and payments and risk teams.
Report to the board on AML risk, control effectiveness and regulatory developments, and maintain the records the Commission expects to see.
Following licence grant, continue as MLRO on a fractional basis, overseeing the framework as the business begins trading and scales.
ICA qualification in anti-money laundering (Advanced Certificate, Diploma or equivalent) is required.
Previous experience as MLRO or deputy MLRO at a Gambling Commission licensed operator, ideally in remote casino or betting, is strongly preferred.
Hands-on experience of a UKGC licence application, variation or compliance assessment is a significant advantage.
Working knowledge of the Money Laundering Regulations 2017, POCA, the Commission's LCCP and its AML guidance for remote casino operators.
Practical experience of CDD, EDD, source of funds reviews, transaction monitoring and SAR decision-making in a high-volume online environment.
Able to satisfy the Commission's integrity and competence checks, and willing to hold a Personal Management Licence if the position requires one.
Confident working directly with founders and licensing solicitors, and able to build a framework from scratch with limited internal resource.
Day rate of £800–£1,000, depending on experience.
Fully remote and flexible, with hours concentrated around the licence application and settling to around a day a week afterwards.
A named MLRO appointment on a new UKGC licence, with influence over the business's AML framework from the outset.
Long-term fractional engagement that continues beyond licence grant.
Fits alongside other fractional MLRO or compliance appointments.
