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Despite competitive remuneration and strong institutional demand, UK banks continue to face persistent challenges in hiring Heads of Compliance and MLROs.
On paper, the talent pool exists. In practice, the gap keeps widening.
In today’s regulatory landscape, these roles often fall under SMF16 (Head of Compliance) and SMF17 (MLRO) within the Senior Managers & Certification Regime (SMCR). While the framework was designed to strengthen accountability, it has also unintentionally reshaped the risk calculus for senior compliance professionals.
1. Personal accountability without proportional authority
Many Heads of Compliance and MLROs carry significant personal regulatory exposure, yet operate without full control over budgets, systems, or strategic decisions. Accountability is high; influence is not always aligned.
2. The judgment dilemma
Modern compliance leadership is no longer about rule interpretation alone. It requires constant judgment calls—balancing commercial objectives, regulatory expectations, and reputational risk. This grey area deters experienced professionals who understand the personal consequences of getting it wrong.
3. Board and executive dynamics
In some institutions, compliance is still viewed as a control function rather than a strategic partner. Where Boards engage reactively instead of proactively, senior compliance leaders often find themselves isolated at critical moments.
4. Regulatory scrutiny and career risk
The reality is simple: failures are visible, personal, and career-defining. Success, by contrast, is often invisible. For many seasoned professionals, the risk-reward equation no longer stacks up.
5. A shrinking succession pipeline
Younger compliance professionals are increasingly selective. Observing the pressures faced by SMF holders, many opt for advisory, consultancy, or non-SMF roles—further tightening the leadership pipeline.
Final thought
The challenge UK banks face is not just about hiring capability. It is about structuring the role, empowering the function, and genuinely integrating compliance leadership into strategic decision-making.
Until that alignment is addressed, the struggle to attract and retain top-tier Heads of Compliance and MLROs will persist.
