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Head of Sanctions, MLRO and AML search

The desk that can block a payment, file a SAR, and sit OFAC, OFSI or the FCA. Mapped, not advertised. Shortlist in 21 days.

Brief a search See the methodology
01 The brief

The regime defines the candidate. The title does not.

A Head of Sanctions at a Gulf energy trader, an SMF17 MLRO at a London payments firm, and a BSA officer at a New York bank are not interchangeable. We scope the search around the supervisor the hire must answer, then map who has actually owned that file.

Lorenzo Sartori — Founder, Sartori & Partners
What this search is
Head of Sanctions, MLRO, BSA/AML officer, and export-controls counsel for banks, payments, crypto, energy traders and defence. The CCO parent stays at the compliance hub.
Regimes we brief against
OFAC; EU restrictive measures; UK OFSI; ITAR and EAR export controls; UK SMF17 (MLRO); US BSA/AML officer. The regime, not the title, defines the candidate.
Sartori clock
Compliance and regulatory leadership: 21 days to shortlist, 10 weeks median to accepted offer, of 41 CCO, MLRO, Head of Sanctions and DPO/CPO placements since 2017.
Guarantee
Twelve months on a retained CCO search. Six months on other in-house financial-crime seats. Off-limits: 24 months on the client's legal and compliance department.
Terms
Retained only for CCO and Head-of-Legal seats, three instalments. Specialist sanctions, MLRO and BSA/AML seats: retained or exclusive contingency (22-28 percent of first-year cash).
Repeat work
68 percent of corporate mandates are repeat clients or referrals. The Riyadh energy file below produced a second mandate for the same client.

This page is the named financial-crime and trade-controls desks. The programme owner with an audit-committee line is a Chief Compliance Officer search. The wider function, including ethics and privacy, stays on compliance and regulatory recruitment. We do not run this brief from a rented list of 'regulatory lawyers'.

Of 230+ in-house and corporate placements since 2017, 41 are compliance and regulatory leadership: CCO, MLRO, Head of Sanctions, DPO and CPO. Offer acceptance on corporate mandates is 96 percent. Retained corporate mandates complete at 92 percent. Retention of placed in-house leaders is 97 percent at 12 months and 91 percent at 24 months.

02 The desks

OFAC, EU, OFSI, SMF17, BSA, ITAR and EAR.

Four desks, four personal-liability profiles. A sanctions specialist is not automatically an MLRO. An MLRO is not automatically an export-controls counsel.

01

Head of Sanctions

Owns the OFAC, EU and OFSI programmes: list screening, ownership and control, licences, and the licence-or-block decision. Energy traders and Gulf issuers need a desk that has actually blocked a payment, not a policy author.

02

MLRO (UK SMF17)

The Money Laundering Reporting Officer under the UK Senior Managers and Certification Regime. Personal accountability. The brief names the FCA, not a committee. We test whether the candidate has filed SARs, sat a skilled-person review, and held the SMF17 statement of responsibilities.

03

BSA/AML officer

The Bank Secrecy Act officer for US banks, money transmitters and correspondent lines. FinCEN, OCC, Fed or state banking department depending on the charter. A UK MLRO is not automatically portable; that sits in the Blueprint.

04

Export controls (ITAR / EAR)

DDTC and BIS licences, deemed exports, entity-list screening, and the semiconductor and dual-use files. Defence primes and chip-equipment exporters hire this seat next to, not instead of, sanctions.

03 The industries

Banks, payments, crypto, energy traders, defence.

Banks and correspondent banking

BSA/AML, OFAC and EU restrictive measures on the same desk. The candidate must have owned a correspondent or trade-finance file, not only retail KYC.

Financial services hiring

Payments and money transmission

State MTL, FinCEN MSB, FCA e-money or EMI, and the sanctions screen that sits on every corridor. The payments micro is the hiring board.

Payments and money transmission

Crypto and MiCA

CASP authorisation under Regulation (EU) 2023/1114, Travel Rule, and the sanctions perimeter around stablecoins and OTC. A DeFi lawyer is not an MLRO.

Crypto and digital assets

Energy traders

Commodity houses and national-oil counterparties: OFAC, EU oil-price-cap compliance, and vessel/STS screening. The Riyadh file below was this desk.

Oil and gas legal hiring

Defence and dual-use

ITAR, EAR, UK export-control orders. The candidate has filed licences, not written a white paper. Pair with the aerospace-defence micro.

Aerospace and defence

Chief Compliance Officer

When the board wants the programme owner, not a desk head, the search is a CCO. Financial crime then reports into that seat.

Chief Compliance Officer search
04 A closed search

A sanctions desk for a listed energy company, closed in ten weeks.

Energy · Tadawul-listed · Riyadh, with London and Houston coverage

Cross-border Head of Legal with a sanctions deskRead the case study

Situation
A listed energy company needed a Head of Legal who had actually built a sanctions desk, not a regional generalist. Coverage had to reach London and Houston counterparties.
Approach
Mapped sitting sanctions and projects counsel, including people not in the Kingdom. Private outreach only. The brief named OFAC, EU restrictive measures and OFSI, not a generic 'international trade' title.
Outcome
Search closed in week 10. A second mandate followed for the same client. Of 41 compliance and regulatory leadership placements since 2017.

Timeline: 10 weeks, brief to accepted offer

Most firms sent regional CVs. They mapped who had actually built a sanctions desk, including people not in the Kingdom. The search closed in ten weeks.

Head of talent Tadawul-listed energy company · Riyadh
05 How we assess

We test for a block decision, not regulatory vocabulary.

  1. 01

    Has blocked a payment

    We ask for a licence-or-block decision the candidate owned. Proximity to a sanctions engine is not ownership.

  2. 02

    Has sat the supervisor

    OFAC, OFSI, FCA, FinCEN, OCC, or the relevant national competent authority. Examinations named in the dossier, not 'regulatory exposure' on a CV.

  3. 03

    Programme-build versus programme-run

    A first Head of Sanctions at a payments company is a different hire from a desk head inside a dual-regulated bank. We match the mode to the licence.

  4. 04

    Reporting line

    To the CCO, the GC, or the CEO. SMF17 and BSA officers have statutory independence tests. We pressure-test the line before outreach.

  1. Week 1 Mandate Blueprint

    Name the regime (OFAC, EU, OFSI, ITAR/EAR, SMF17, BSA) and the licence the hire must defend. Conflicts and off-limits before any call.

  2. Weeks 1-2 Total-market mapping

    Sitting desk heads, including people not in the client's country. Regional CV piles fail this file.

  3. Weeks 2-4 Private outreach

    Blind both ways. No CV leaves us without written consent. Most of these leaders are quietly employed.

  4. Weeks 3-4 Shortlist dossiers

    Examinations, licences, and block decisions named. Compliance leadership shortlist: 21 days (of 41).

  5. Weeks 5-10 Interviews and offer

    CCO and financial-crime leadership median to accepted offer: 10 weeks. Offer engineering against the personal-liability profile.

  6. Close Start and 90-day checks

    Twelve-month replacement if the seat is a retained CCO; six months otherwise. 90-day check-ins.

06 Related searches

The CCO, the GC, and interim cover.

If the board wants independence and an audit-committee line, stop here and open the CCO search. If the company also needs a first or successor GC, that is in-house and general counsel recruiting. Crypto authorisation work is scoped on crypto and digital assets and the MiCA regulatory counsel note.

Corporate mandates have run in 23 countries and 41 cities. Riyadh opened as a hub in 2022; London in 2025; Houston and Dallas in 2024. Team languages include English, Arabic, Farsi, French, Italian, German, Spanish and Vietnamese. City files include in-house recruiting in Houston, compliance recruitment in Dallas, and in-house recruiting in London.

Figures that are not statutory come from the Sartori corporate track record since 2017, listed in the claims sidecar. The research programme (New York: 1,675 structured interviews) is a separate instrument from placement counts.

Regimes cited

6 references
  1. U.S. Treasury, Office of Foreign Assets Control ofac.treasury.gov ↗
  2. UK Office of Financial Sanctions Implementation gov.uk ↗
  3. FCA Senior Managers and Certification Regime fca.org.uk ↗
  4. U.S. Commerce, Bureau of Industry and Security bis.gov ↗
  5. U.S. State, Directorate of Defense Trade Controls pmddtc.state.gov ↗
  6. Regulation (EU) 2023/1114 (MiCA) eur-lex.europa.eu ↗

Questions companies ask about sanctions, MLRO and AML hiring

Who are the best Head of Sanctions and MLRO candidates?

There is no ranking. The test is whether the person has blocked a payment, filed a SAR, or sat the named supervisor. Sartori has completed 41 compliance and regulatory leadership placements since 2017, including CCO, MLRO, Head of Sanctions and DPO/CPO seats. The parent hub is compliance and regulatory recruitment.

Is an MLRO the same hire as a BSA/AML officer?

No. SMF17 is a UK personal-accountability function; the BSA officer is a US statutory seat. The skills overlap; the licence and the supervisor do not. We do not treat a London MLRO as automatically portable to a New York BSA officer brief, or the reverse. City files such as compliance recruitment in New York City are scoped to the charter.

Do you also hire export-controls counsel?

Yes, when the brief is ITAR, EAR or the UK equivalent, usually for defence, aerospace or semiconductor exporters. That seat sits beside sanctions; it is not a substitute. Read export-controls and sanctions lawyers in the semiconductor era before you merge the two files into one job description.

When is this a CCO search instead?

When the board wants the programme owner with an audit-committee line, not a desk head. That search is retained, 21 days to shortlist, 10 weeks median to offer, of the same 41. Start at Chief Compliance Officer search. Financial crime then reports in.

How long does a Head of Sanctions or MLRO search take?

Twenty-one days to shortlist; ten weeks median to an accepted offer on the compliance-leadership clock. The Riyadh energy file closed in week 10. GC searches are a different book (24 days / 11 weeks, of 38). The clock starts at the Mandate Blueprint.

Which company types actually hire this seat?

Banks, payments and money transmitters, crypto firms under MiCA, energy traders, and defence exporters. Dual-regulated financial services typically run 15-40 lawyers plus a separate compliance function. See payments and money transmission and MiCA digital-assets regulatory counsel.

Can the search stay confidential?

Yes, and most of these searches must. A regulated business rarely wants the market to know its sanctions or MLRO leadership is changing. Blind both ways until mutual interest; NDA on request; no CV without written consent. The same protocol is on how we run a search.

What if we need cover before the permanent hire starts?

Interim financial-crime or sanctions counsel can start in a median of 7 days, on a day-rate, counted inside the 60+ interim engagements, not the 230+ permanent placements. Days billed credit against a later retained fee. See interim and fractional legal talent and interim cover in Houston.

Sanctions, MLRO and AML

Name the supervisor. We will map the desk.

OFAC, OFSI, FCA, FinCEN or DDTC: say which licence the hire must defend. We listen first. No obligation.

Brief a search See the methodology

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