Why a Combined Role Needs a Careful Job Description

A job description for most senior roles is a recruitment tool. For a compliance officer and MLRO, it does more. It sets out what the firm expects the person to be accountable for, it should line up with their Statement of Responsibilities, and it shows the regulator, candidates and the board that the firm has thought about how two significant functions fit into one role.

A vague job description causes problems at every stage. Strong candidates are put off because they can’t see what the role involves or whether it is realistic. The approval application is harder to support if the documents don’t match. And once the person is in post, unclear responsibilities lead to gaps, particularly between compliance and financial crime. Our guide to the SMF16 and SMF17 functions explains what each involves.

What’s in the Template

Grey guidance notes in the template explain what to include in each section. Delete them before you use it.

How to Complete It

• Start with the firm. Write the purpose statement around your activities, permissions and customers. A compliance officer and MLRO at a small advice firm is a different job from one at a payments business.
• Set the time commitment honestly. Full-time, a number of days a week, or a number of days a month. Our guide on how many days a week the role needs helps you size it.
• Tailor the responsibilities. Keep the core duties, then add sector-specific ones such as suitability, affordability, CASS oversight or safeguarding. Remove anything that doesn’t apply.
• Match the Statement of Responsibilities. Write the two documents together so they describe the same accountabilities. Our Statement of Responsibilities template includes example wording for SMF16 and SMF17.
• Be specific about experience. Name the sector and the regulatory areas that matter most. Generic requirements attract generic candidates.
• State the approval conditions. Make clear that any offer is conditional on checks, references and FCA approval, so candidates know what to expect.

Getting the Reporting Line Right

Both functions need independence and direct access to the board. A compliance officer and MLRO who reports only to a sales or commercial director will raise questions with candidates and the regulator alike. Most smaller firms have the role report to the chief executive or managing director, with a direct line to the chair or the audit or risk committee. Our article on when the managing director is also the compliance officer covers the independence issues in detail.

Building in Independent Review

When one person holds both functions, the compliance officer is effectively checking their own financial crime work. A good job description recognises that and includes responsibility for arranging independent review of the anti-money laundering framework, such as an annual external review. It signals to candidates and the regulator that the firm understands the limits of the combined arrangement. Our article Who Checks the Checker? explains the options.

Common Mistakes

• Copying a large firm’s job description. A bank’s MLRO role description will overwhelm a small firm’s candidate and misdescribe the job.
• Listing everything as essential. It narrows the pool to almost nobody. Keep essentials to what the role genuinely needs from day one.
• Leaving out time and resources. Candidates want to know whether the role is realistic. Say what support and budget exist.
• Ignoring the approval process. Candidates with experience of regulated roles will expect conditional offers. Leaving it out looks inexperienced.
• Treating the MLRO part as an add-on. In many firms, financial crime is the bigger risk. Give it equal weight.

Using the Job Description in the Search

The job description is the starting point for the advert, the interview plan and the assessment. Build interview questions around the responsibilities in sections 3 and 4, and test judgement as well as knowledge. Our guide to interviewing a combined compliance officer and MLRO suggests the questions that separate strong candidates from adequate ones, and our article on what a combined compliance officer and MLRO costs helps you set the package in section 8.

When the role is ready to go to market, SMF Capital’s compliance officer and MLRO recruitment service can run the search, with every candidate assessed against the fit and proper test before they reach your shortlist.

Example: A Completed Role Summary

Here is how the role summary and purpose might read for a small directly authorised advice firm:

Notice how specific it is: the reader can see the firm’s size, activities, time commitment and independence arrangements at a glance. That is what good candidates look for.

When to Split the Role Instead

A combined compliance officer and MLRO suits many smaller firms, but not all. Firms with high financial crime risk, such as payments, e-money and cryptoasset businesses, or firms with rapidly growing volumes, often need separate appointments. If writing the job description shows that the role won’t fit into one person’s time, that is a sign to consider two roles. Our article on when to split a combined SMF16 and SMF17 role sets out the signs, and our pages on compliance officer recruitment and MLRO recruitment cover separate appointments.

Frequently Asked Questions

Is the template free?

Yes. Download it and adapt it for your firm, with no sign-up. It’s general guidance, not legal or regulatory advice.

Does the job description need to match the Statement of Responsibilities?

It should. The Statement of Responsibilities is the regulatory document, but a job description that describes different accountabilities causes confusion and can undermine the approval application.

Can the template be used for a fractional role?

Yes. Set the time commitment and basis in section 1, and adjust the responsibilities to what can realistically be delivered in the agreed days.

Can I use it for separate compliance officer and MLRO roles?

Yes. Use sections 3 and 4 as the core of two separate job descriptions, and adjust the role summary, experience and package for each.

Should the salary be in the job description?

Including a range attracts more relevant candidates and saves time. Many firms share it with candidates through their recruiter rather than in a public advert.