Clearhaven provides fractional Chief Compliance Officer and Money Laundering Reporting Officer services to fintechs, payment firms and crypto-asset service providers.

We work as part of your leadership team, taking ownership of regulatory priorities, financial crime controls and the day-to-day development of your compliance function.

Experienced leadership at the point you need it

A growing regulated business may need senior compliance leadership before it is ready to make a permanent hire. An existing CCO or MLRO may leave during an authorisation application, regulatory review or important stage of growth.

Our fractional and interim compliance specialists provide continuity, judgement and clear ownership during these periods.

We can support firms that are:

• Preparing for fintech or CASP authorisation

• Launching a regulated product

• Entering the UK or European market

• Building their first compliance function

• Scaling transaction volumes or customer numbers

• Managing a regulatory review

• Delivering a remediation programme

• Recruiting a permanent CCO or MLRO

• Strengthening an existing compliance team

The scope and time commitment are agreed around the business, its regulatory status and its risk profile.

Fractional Chief Compliance Officer services

A fractional CCO gives founders and boards an experienced compliance leader who can turn regulatory requirements into a workable programme.

Our fractional CCO services can include:

• Regulatory strategy and compliance planning

• Advice to founders, boards and senior management

• Fintech, payment institution, EMI and CASP authorisation

• Regulatory engagement and correspondence

• Compliance risk assessments

• Compliance policies and procedures

• Compliance monitoring programmes

• Board reporting and management information

• Product and market launch reviews

• Consumer Duty and customer outcomes

• Safeguarding governance

• Outsourcing and third-party oversight

• Operational resilience and DORA

• Regulatory reporting and notifications

• Training and compliance culture

• Management of regulatory findings

• Compliance team recruitment and development

The fractional CCO works closely with product, operations, engineering, finance and customer teams. Compliance decisions are made with a clear understanding of how the product and customer journey operate.

Fractional MLRO services

The MLRO needs enough seniority, independence, information and access to challenge the business effectively.

Our fractional and interim MLRO services can cover:

• Business-wide financial crime risk assessments

• AML and counter-terrorist financing frameworks

• Customer risk-rating methodology

• KYC and customer due diligence

• Enhanced due diligence

• PEP and sanctions screening

• Transaction monitoring

• Blockchain analytics and wallet screening

• Suspicious activity reporting

• Fraud and financial crime investigations

• Source of funds and source of wealth controls

• Financial crime management information

• Board and senior management reporting

• AML training

• Quality assurance and control testing

• Regulatory enquiries and information requests

• Backlog management and remediation

We establish a clear view of the firm’s financial crime exposure and make sure the available resources are focused on its highest-risk customers, products and transactions.

Fractional compliance for crypto and CASPs

Crypto compliance requires a detailed understanding of the product, the assets involved and how transactions move across wallets, platforms and jurisdictions.

We support crypto exchanges, custodians, brokers, trading platforms, wallet providers, stablecoin businesses and other digital asset firms.

Our work can include:

• MiCA and CASP compliance

• UK cryptoasset regulation

• AML and sanctions risk

• Crypto transaction monitoring

• Blockchain analytics

• Wallet screening and attribution

• Travel Rule compliance

• Custody and client asset controls

• Token and asset onboarding

• Market abuse surveillance

• Conflicts of interest

• Cross-border services

• ICT risk and DORA

• Regulatory reporting

• Banking and payment partner requirements

We can also help an existing VASP or crypto business prepare its compliance function for a broader CASP authorisation assessment.

Fractional compliance for fintech and payments

For payment firms and electronic money businesses, the compliance function needs to stay connected to the movement and protection of customer funds.

Our fractional leaders can oversee:

• Payment institution and EMI requirements

• Safeguarding arrangements

• Customer funds and reconciliation governance

• Financial crime controls

• Fraud risk

• Complaints and customer outcomes

• Agent and distributor oversight

• Outsourcing arrangements

• Regulatory returns and notifications

• Wind-down planning

• New products and partnerships

• Board compliance reporting

This support can begin during authorisation and continue through launch, regulatory supervision and growth.

Engagement models

Fractional CCO or MLRO

Ongoing senior compliance leadership for an agreed number of days each month. This works well for early-stage and scaling firms that require regular executive input.

Interim CCO or MLRO

Short-term leadership during recruitment, restructuring, authorisation, remediation or an unexpected vacancy.

Support for an existing CCO or MLRO

Additional senior capacity for a major application, product launch, regulatory review or financial crime programme.

Build and handover

We establish the compliance function, recruit or prepare the permanent team and complete a structured handover when the business is ready.

Any named or regulated appointment is subject to the requirements of the relevant jurisdiction, the firm’s permissions and, where applicable, regulatory approval.

What the first 90 days can cover

Establish the position

We review the business model, regulatory obligations, open issues, control environment and current compliance workload.

Set priorities

Immediate risks are separated from longer-term improvements. Each action has a clear owner, timetable and expected outcome.

Build the operating rhythm

We establish reporting, governance, monitoring and escalation arrangements that fit the pace of the business.

Strengthen the team

We identify capability gaps, support recruitment and help existing staff take on greater responsibility.

Prepare for what comes next

The compliance programme is aligned with the firm’s authorisation plans, product roadmap and target markets.

Senior practitioners working inside your business

Our fractional CCO and MLRO services are delivered by practitioners with more than 20 years of experience across regulation, industry and consulting.

The team includes former leaders of regulatory units, Heads of Compliance, MLROs, COOs, CEOs and Big Four partners. They have led authorisation applications, financial crime investigations, regulatory reviews and complex remediation programmes.

You work directly with the person responsible for delivering the engagement. They participate in management discussions, engage with the board and stay close to the teams operating the controls.

Put experienced compliance leadership into the business

Tell us about your product, regulatory status and current priorities. We will help you determine the level of CCO or MLRO support the business requires.