Interim MLRO and compliance secondment
Your compliance officer is leaving, a supervisory examination has landed, or a licence application needs more capacity than you have. We fill the gap with someone who has carried the role himself — as MLRO of regulated institutions in the Netherlands, France and Poland.
What is an interim compliance officer?
An interim compliance officer is an experienced compliance professional who temporarily fills or reinforces the compliance function inside your organisation. They work within your policies, your governance and your systems, but bring experience from comparable institutions. The engagement is bounded in advance by days per week and duration, and ends with a documented handover.
An interim MLRO goes further: they also carry responsibility for the AML/CFT framework and for reporting unusual transactions to FIU-the-Netherlands. That role demands mandate, seniority and direct access to the board — a deliberate choice, not casual hire.
When institutions call us
Departure or absence
The compliance officer or MLRO leaves, falls ill or goes on leave. Leaving the role vacant is not an option, particularly when the supervisor has recorded the position in your licence.
Licence application
A MiCAR, payments or trust licence demands months of above-average capacity. Temporary reinforcement is cheaper than a permanent hire you cannot keep busy afterwards.
Examination or remediation
DNB or the AFM has issued findings and a remediation deadline is running. You need someone who knows how those processes work from the inside.
Too small for a full role
You are an obliged entity but do not have work for a full-time compliance officer. A fixed number of hours per month gives continuity without the headcount.
Three engagement models
| Model | What it involves | Suited to |
|---|---|---|
| Secondment | Two to five days a week on site, for a defined period of typically three to twelve months. | Cover, licensing projects, remediation programmes |
| Interim MLRO | Formal fulfilment of the MLRO role, including assessment of reports, escalations, and reporting to the board and supervisor. | Institutions without an MLRO or with a vacancy in that position |
| MLRO-as-a-service | A fixed number of hours per month on retainer: escalations, reporting decisions, policy maintenance, quarterly board reporting. | Smaller CASPs, payment institutions, EMIs and trust offices |
Who you get
Engagements run through Tarik Binnekade, senior advisor and MLRO at ZandKade Compliance. He carried responsibility for the AML/CFT framework of regulated crypto-asset service providers in the Netherlands, France and Poland: suspicious transaction reporting, high-risk client onboarding, financial crime governance, and reporting to senior management and the board. He has handled supervisory examinations and MiCAR licence readiness. He also holds a PhD in neuropsychology — which becomes visible the moment the conversation turns to why signals get missed in practice.
On larger engagements we add analysts under his quality control, so volume does not cost quality. More about Tarik and Mitchell →
What it costs
- Secondment and interim MLRO: day rate from € 1,100 excluding VAT, depending on complexity, sector and duration. Engagements beyond six months carry a reduced rate.
- MLRO-as-a-service: from € 1,750 per month excluding VAT for eight hours, including quarterly board reporting. Extendable in blocks of four hours.
- Notice period: one month for secondment, three months for MLRO-as-a-service — so you are never left without an identifiable responsible person.
Not a staffing agency. We do not forward CVs at a margin. You speak to the person who does the work, and that person stays accountable until the handover is complete.
Frequently asked questions
What is an interim compliance officer?
An interim compliance officer is an experienced compliance professional who temporarily fills or reinforces the compliance function inside your organisation — during sick leave or parental leave, after the permanent officer resigns, during a licence application, or while a supervisory examination is running. They work under your policies and governance but bring outside experience. The engagement is bounded up front in days per week and duration.
What does an MLRO do?
The MLRO (Money Laundering Reporting Officer) is responsible for the institution's AML/CFT framework and for reporting unusual transactions to the Dutch Financial Intelligence Unit, FIU-the-Netherlands. In practice: assessing alerts and escalations, deciding on reports, approving high-risk clients, maintaining policy and risk assessment, liaising with the supervisor, and reporting to senior management and the board on how effective the framework actually is.
When does a firm operating in the Netherlands need an MLRO?
As soon as you qualify as an institution under the Dutch AML Act (Wwft), someone must be identifiably responsible for the reporting process and the AML/CFT framework. For licensed institutions — banks, payment institutions, e-money institutions, crypto-asset service providers, trust offices — the supervisor also expects the role to sit with a fit and proper individual who has enough time, mandate and seniority. Smaller firms often place part of that role externally.
What does an interim compliance officer or MLRO cost?
For senior interim work we charge a day rate from € 1,100 excluding VAT, depending on complexity, sector and duration. For institutions that do not need a full position, we offer MLRO-as-a-service as a monthly subscription from € 1,750 excluding VAT for eight hours a month. Longer engagements carry a lower rate, agreed in advance.
How quickly can someone start?
Our senior advisor and MLRO Tarik Binnekade is fully available, up to five days a week. In an acute situation — a departing compliance officer, an announced supervisory examination — we can usually start within one to two weeks. For a planned handover, two to four weeks is normal.
Can the engagement be part-time or remote?
Yes. Most engagements run two to four days a week, with one fixed day on site and the rest remote. For smaller institutions a set number of hours per month often works better than whole days: you keep continuity without carrying a full position.
Will you take formal responsibility as the appointed MLRO?
We can, but not unconditionally. Formal appointment as MLRO or as a day-to-day policymaker requires sufficient mandate, access to systems and data, and direct access to the board. We agree those conditions in writing before we start; without them we decline the role.
Sources
- Dutch Anti-Money Laundering and Anti-Terrorist Financing Act (Wwft) — wetten.overheid.nl
- Wwft — Open Boek Toezicht, De Nederlandsche Bank
- FIU-the-Netherlands
- De Nederlandsche Bank (DNB)
- Autoriteit Financiële Markten (AFM)
Related
No concrete vacancy yet, but a risk you can see? In a thirty-minute call we work out whether you need a temporary solution or should be recruiting. We would rather sell nothing than the wrong engagement. Book a call.