Fractional MLRO — UK Bridging Finance / Sharia-Compliant Property Lending

Engagement type: Fractional / part-time, ongoing retainer (with scope to flex up during FCA application phase) Location: Remote (UK-based candidates only — must be eligible to act as a UK-regulated MLRO) Start date: ASAP About us Covenant Capital Fintech Ltd is a UK fintech building a short-term property lending business with a Sharia-compliant product set, including a two-tier commodity murabaha structure for property financing. We are in the process of preparing our FCA Annex 1 registration under the Money Laundering Regulations 2017 and are building out our compliance, legal, and operational infrastructure from the ground up. We have already drafted a full AML/CTF/CPF framework — a redrafted firm-wide AML policy plus nine supporting documents covering the business-wide risk assessment, proliferation financing, CDD/KYC, SAR procedures, sanctions screening, training, MLRO reporting, and record-keeping. We are now looking for an experienced MLRO to review, sign off on, and own this framework on a fractional basis as we move through registration and into live operations. The role: You will act as our nominated Money Laundering Reporting Officer, taking statutory responsibility for the firm's AML/CTF/CPF regime. This is a hands-on fractional role — you will not be a figurehead. You'll work directly with the founders to finalise our submission, then provide ongoing oversight as we onboard clients and counterparties. Key responsibilities: - Act as the firm's nominated MLRO and primary point of contact with the FCA, NCA, and HMRC on financial-crime matters. - Review and approve our existing AML policy suite (CCF-AML-000 through CCF-AML-009) and business-wide risk assessment; recommend revisions where needed - Support the FCA Annex 1 application — including responding to FCA queries, attending - interviews if required, and ensuring the AML framework is defensible under scrutiny - Own the firm's SAR process: review internal reports, file SARs with the NCA where appropriate, and maintain the SAR register - Oversee CDD/EDD, sanctions screening, and PEP checks on borrowers, investors, commodity brokers, and other counterparties — particularly given the commodity murabaha flows involving multiple parties - Provide AML training to staff and maintain training records - Produce the annual MLRO report to the board - Keep the framework current as regulation, FCA guidance, and our product mix evolve - Advise on financial-crime risk in new product design and commercial agreements Required experience - Demonstrable experience as a nominated MLRO at an FCA-regulated or FCA-registered UK firm (Annex 1 firms, lenders, payment institutions, or similar) - Strong working knowledge of MLR 2017, POCA 2002, the Terrorism Act 2000, OFSI sanctions regime, and JMLSG guidance - Direct experience with FCA Annex 1 registration or comparable FCA authorisation processes - Relevant qualification — ICA Diploma in AML, ACAMS, or equivalent - Comfortable working in a small, fast-moving founder-led environment with limited handholding Nice to have Experience with bridging / short-term property lending or specialist real-estate finance Familiarity with Islamic finance structures, particularly commodity murabaha and the financial-crime considerations specific to commodity-broker flows Prior experience standing up a compliance function from scratch (rather than inheriting one) Engagement details - Initial estimated commitment: ~1–2 days per week during the FCA application phase, tapering to roughly half a day to one day per week in BAU - Fully remote; occasional video calls with the founding team - We will consider both day-rate and monthly retainer proposals — please indicate your preferred structure To apply Please send: A short cover note explaining your relevant MLRO experience, with specific reference to any Annex 1 or comparable FCA work Your CV Your proposed rate (day rate or monthly retainer) and current availability Confirmation that you are UK-based and eligible to act as a nominated MLRO Shortlisted candidates will be invited to a 30-minute introductory call with the founders, followed by a working session reviewing a redacted extract of our existing AML framework.