We hear the same sentence at least once a month, usually from a founder who is running out of patience. “We’ve been looking for an MLRO since January. Two agencies. Nothing.”
Then comes the assumption that follows it: there just aren’t enough qualified people out there.
There are. Across Lithuania, Poland, Germany, and the UK, we can name the credible candidates for most compliance leadership roles. The pool is small, but it is not empty. When a search runs for six months and produces nothing, the constraint is almost never supply. It is one of four structural problems, and all four are fixable.
1. Your salary band was set before the market moved
Compliance leadership pay has moved faster than almost any other fintech function over the last two years, and most internal bands have not caught up. Licensing pressure across the EU created simultaneous demand for the same narrow group of people, and salaries responded the way they always do when demand concentrates.
The symptom is easy to spot. Your recruiter delivers candidates, those candidates take the first call, and then they disappear at the compensation conversation. Nobody says no outright. They just stop replying.
If two or more good candidates have dropped out at that stage, the problem is not the candidates. Benchmark against what people actually accepted in the last six months, not what was advertised. Those are different numbers.
Quick check
Ask your agency for the last three accepted offers they placed at this level, anonymised. If they can’t tell you, they don’t have the market data to advise you on your band.
2. The brief is asking for two different people
This one is common in scaling companies. The job description asks for someone who has held an MLRO position at a licensed institution, has scaled a compliance function from scratch, is comfortable in a startup with no processes, and will personally handle day-to-day transaction monitoring.
That is not one person. It is a Head of Compliance and a compliance analyst, described as a single hire because the budget only has one line for it.
Candidates who could do the strategic half will not do the operational half, and candidates happy with the operational half won’t get the regulator comfortable. The search stalls because the target doesn’t exist.
“Six months of searching usually means six months of looking for someone who was never there.”
The fix is uncomfortable but simple: decide which half of the role is the one you cannot compromise on, hire for that, and solve the other half differently. Sometimes that means a fractional MLRO for the licence and a junior analyst for the volume. It is cheaper than another six months of nothing.
3. Your process is slower than your competitors’
Compliance leaders are, by definition, employed. They are not browsing job boards. When one does agree to a process, they are usually in two or three others at the same time, and they are being courted by companies who have done this before.
A five-stage process with a case study, a panel, and a two-week gap between rounds does not read as thorough to that person. It reads as indecisive. They take the offer that arrived first from the company that seemed to know what it wanted.
The companies that win these hires have collapsed the process to two or three stages, with decision-makers in the room from the first conversation. Speed here is not a compromise on rigour. It is a signal of seriousness.
What that looks like in practice
- Stage one: founder or CEO, 45 minutes, mutual sell.
- Stage two: technical and regulatory deep dive with whoever owns the licence relationship.
- Stage three: a short conversation with the board member who signs off, and a decision the same week.
Three stages, ten days, offer out. That process wins candidates against companies that pay more.
4. Nobody has told you the truth
This is the quiet one, and it underpins the other three.
Most agencies are paid on placement. That means the incentive is to keep the search alive, keep sending CVs, and keep hope in the room, because a search that gets cancelled pays nothing. Telling a client that their band is wrong, their brief is incoherent, or their process is losing them people risks the relationship and the fee.
So it doesn’t get said. The search runs. CVs arrive. Nothing closes. Six months pass.
We built our business on the opposite instinct, and it costs us money regularly. If a search shouldn’t run, we say so on the discovery call. If the band is 12% under market, we tell you before we start, not after three candidates have walked. It has cost us fees. It has also meant that the clients who stay, stay for years.
Where to start
If you’re six months in, don’t brief a third agency. Take a week and audit the search instead:
- Pull your last five candidate drop-offs and find the stage they died at. That stage is your problem.
- Re-benchmark the band against accepted offers, not advertised ones.
- Read the job description out loud and ask honestly whether it describes one person.
- Count your interview stages and your average gap between them.
Most stalled compliance searches are fixed by two of those four. None of them require a bigger candidate pool.
