For financial services firms, this means financial crime functions cannot rely solely on processes. Technology can identify patterns, screen transactions and help teams analyse increasingly large volumes of information, but experienced people still need to interpret what those systems are telling them. Judgement becomes particularly important when dealing with complex ownership structures, unusual customer behaviour, higher risk jurisdictions or activity that falls outside established patterns without necessarily being criminal.

Regulatory expectations are reinforcing the importance of that expertise. Recent FCA work on customer due diligence examined CDD, enhanced due diligence and ongoing due diligence controls across different types of financial services firms, while separate work identified potential weaknesses in financial crime frameworks within parts of the corporate finance market. The FCA has also highlighted the increasing complexity of UK sanctions regimes and the need for firms to maintain appropriate systems and controls.

This creates an interesting recruitment market. Financial crime professionals are needed across a wide range of institutions, which means employers are often competing for similar experience. A strong investigator may understand fraud patterns and case management, while an experienced AML professional may have deeper expertise in customer risk, source of wealth or complex ownership structures. Sanctions specialists bring another set of skills, while senior financial crime leaders increasingly need to understand all of these areas while communicating effectively with boards, regulators and commercial teams.

For financial crime recruitment agencies, understanding those distinctions matters. Treating every requirement as a generic compliance vacancy can produce technically plausible candidates who are poorly matched to the actual risks facing the business. A wealth manager dealing with complex private clients and international wealth requires a different financial crime skill set from a specialist lender assessing borrower activity, or an asset manager dealing with institutional investors and complex investment structures.

The same applies to fraud recruitment agencies. Fraud itself covers a broad range of activities, from payment and identity fraud through to application fraud, investment scams and increasingly sophisticated forms of digital deception. Employers need to understand whether they require investigators, prevention specialists, analysts, operational leaders or senior professionals capable of designing an entire fraud control framework. Hiring successfully begins with defining the problem rather than searching for a familiar job title.

There is also a growing need for people who can connect financial crime expertise with technology. Artificial intelligence and increasingly sophisticated analytics should allow firms to review greater volumes of data and identify suspicious activity more effectively, although technology also creates new risks.

The financial crime professionals likely to become most valuable over the coming years will be those who understand how technology can improve controls without assuming that automated outputs remove the need for human judgement.

This makes assessment particularly important. Qualifications and experience provide useful evidence, but firms should also explore how candidates think. Can they challenge established processes when something does not look right? Do they understand the commercial environment in which controls operate? Can they distinguish between genuinely suspicious behaviour and activity that is simply unusual? At leadership level, can they explain financial crime risk clearly enough for a board to understand where investment and attention are required?

Capacity matters too. Financial crime functions can become stretched quickly when regulatory projects, remediation exercises or unexpected increases in cases coincide with normal workloads. The FCA itself emphasises that firms should consider whether senior candidates have sufficient time and resources to fulfil their responsibilities without becoming overstretched. In these situations, contractors can provide valuable additional capability, particularly where firms require experienced professionals for investigations, remediation, control reviews or periods of organisational change without necessarily creating permanent roles.

At Fram Search, we recruit permanent and contract professionals across wealth management, asset management, venture capital, asset finance and specialist lending. Financial crime sits across these markets rather than belonging to one type of institution, and our specialist sector knowledge helps us understand the environment candidates will be working within as well as the technical requirements of the role. We support clients looking for professionals across financial crime, compliance, risk and related control functions, with a search process focused on capability, judgement and cultural alignment rather than simply matching keywords on a CV.

The demand for strong financial crime professionals is unlikely to disappear. Criminal methods will continue to change, regulatory expectations will evolve and technology will alter both the threats firms face and the tools available to combat them. Businesses that treat financial crime talent as an important part of their wider risk strategy, rather than recruitment undertaken only when teams become overwhelmed, will be better placed to protect their clients, reputation and organisation.

Successful firms recognise that hiring well is not just about experience, but alignment, timing and intent. Contact Fram Search if we can ever assist you with insights on the issues raised.