Financial Crime Compliance
Demand for financial crime resources across financial services firms continued to increase during 2022.
Large-scale s.166’s/investigations have led to an aggregate increase in financial crime population growth, with firms bolstering their teams in most cases with junior and more operational hires. There has been significantly less hiring of financially crime-focused MDs/Directors/single discipline MLROs than in 2019 as institutions benefit from the tools and procedures/processes that the senior population have embedded over the past 24 months.
Compensation growth has been somewhat muted. Salary bands have broadly increased in the last 12 months (below inflation rates). The AVP/ VP (Manager/ Senior Manager) population have experienced higher salary growth and remains “within the band” of the larger firms that can dictate pricing points.
Tier-one financial service institutions have broadly increased the upper limits of their respective salary bands – per corporate grade. However, this increase remains short of inflation. Most larger firms are now expanding their headcounts and are operating at the upper limits of compensation bands.
- The number of candidates that progress to the following corporate band remains limited.
- The increased competition for more senior positions puts downward pressure on compensation growth. With numerous large-scale team builds going on across the city, this puts significant pressure on retention.
For obvious reasons, the area with the highest level of hiring has been within sanctions. First-line advisory and governance/assurance-based roles remain one of the highest areas of demand, with available talent remaining tight. Candidates have also benefited from increased demand for contractors/project managers in this space, with numerous lucrative short-term opportunities available within the market.
increase in assurance/governance/ risk assessment hiring during 2022
Candidates that can create, write, and translate policy across all domains remain in high demand. The Financial Sanctions and Terrorist Financing market is expected to remain tight well into 2023 as the largest recorded events since the Megarian Decree (432 BC) show no sign of abating.
In contrast, there has been a reduction in hiring at the Director level and above.
- AB&C Senior operators have been hit particularly hard as efficiencies are evident post-UK BA implementation.
- Tier 2 & 3 institutions have fallen back to a harmonised model of co-head of compliance and MLRO (against the commentary of the FCA).
increase in sanctions hiring during 2022
David Paine
Associate Director