Why MLRO Tenure Needs Reframing

In the conversations I have with senior compliance professionals across fintech and financial services, one theme keeps surfacing: how MLRO candidates are being assessed during hiring. More specifically, how quickly a shorter tenure on a CV is treated as a warning sign.

I understand the instinct. In most leadership roles, longevity reads as resilience – proof of fit, of judgement, of an ability to stay the course. But the MLRO role doesn’t work like other leadership roles and applying that conventional lens is increasingly leading firms to misread the candidates in front of them.

The role has changed, but hiring hasn’t caught up

Regulatory expectations have risen sharply. Financial crime oversight is more data-led, more scrutinised, and more personally exposed than it was even a few years ago. The FCA expects firms to appoint an MLRO with clear responsibility for the oversight of AML systems and controls, and JMLSG guidance sets equally firm expectations around senior management accountability. Under SMCR, the MLRO sits within SMF17 – a recognised senior management function carrying real personal liability.

That changes the equation. When you’re hiring someone whose name will sit on the regulatory line, the question isn’t really how long they stayed somewhere. It’s whether they had the authority, support, and infrastructure to do the role properly while they were there.

The wrong question

When I see hiring teams default to “why did they leave so soon?”, I often feel they’re starting from the wrong place. A more useful question when it comes to legal and compliance functions is, “What conditions made it difficult for them to stay?”

A shorter tenure can reflect any number of structural issues that have very little to do with the individual: weak governance support, underinvestment in controls, unclear reporting lines, cultural misalignment, or – most commonly in my experience – high accountability paired with insufficient authority. In many cases, the person isn’t the problem. The environment is.

That matters because the strongest MLROs I speak with are doing exactly what good senior compliance leaders should do – assessing firms as carefully as those firms are assessing them. They’re asking whether the board is genuinely engaged, whether reporting lines are clean, whether there’s real investment in compliance infrastructure, and whether financial crime prevention is genuinely prioritised or quietly treated as a cost centre. Those answers shape tenure far more than ambition or loyalty ever will.

Long tenure isn’t always what it looks like

I’m not suggesting longer tenures don’t matter – they often reflect stability, mature governance, and strong institutional support. But long tenure can also reflect a lower-risk environment, or simply a less demanding mandate. Equally, a shorter tenure can reflect strong professional judgement: a clear-eyed understanding of personal liability and the discipline to recognise when a role isn’t set up to succeed.

The market context reinforces this. Movement at the SMF16 and SMF17 level is no longer unusual. It frequently reflects the structural pressure attached to the function rather than any failing on the part of the individual. Firms that continue to read shorter tenures through an outdated lens risk filtering out exactly the candidates they need.

Fintech’s pressure points

This feels especially relevant in fintech. Businesses are scaling quickly, expanding into more regulated markets, and building governance structures in parallel with growth. That creates a particular challenge: a firm may successfully attract ambitious senior compliance leadership but still lack the infrastructure, authority, or executive alignment needed to make the role sustainable.

In those environments, a shorter tenure shouldn’t automatically raise suspicion. It should prompt a more honest reflection on whether the role was genuinely designed for success. Without that support, even the most capable MLROs will struggle to make long-term tenure realistic.

A better way to assess

If compliance leadership is treated as a box-ticking function, turnover will stay high. But when MLROs are positioned as strategic leaders – with genuine authority, executive backing, and proper governance around them – retention becomes a far more realistic outcome.

The more useful question, in my view, is impact. When assessing a candidate, I’d encourage hiring teams to ask: did they leave the organisation stronger than they found it? Did they improve control effectiveness, mature the governance framework, or build something capable of standing up to regulatory scrutiny? Did they manage regulatory relationships well? Did they recognise and escalate risk appropriately?

If the answer is yes, then a shorter tenure isn’t instability. In many cases, it reflects sound judgement and a clear understanding of personal accountability.

The MLRO role has evolved. It’s more demanding, more visible, and more personally exposed than many firms fully appreciate. That reality should shape how we hire, assess, and talk about tenure. Stability isn’t really a function of time – it’s a function of whether someone was empowered to do the role properly, and the impact they delivered as a result.

Connect with our Legal & Compliance Specialists

For further support and market insights regarding legal and compliance hiring please get in touch with our legal & compliance global specialists: