Control Functions
Head of Compliance and MLRO Search in Ireland
Approvable compliance leaders for Central Bank regulated firms
Phoenix Search runs retained executive search for Heads of Compliance, Money Laundering Reporting Officers (MLROs) and Heads of AML at firms regulated by the Central Bank of Ireland. From Dublin, we work with fund administrators, depositaries, fund management companies, payment and e-money institutions, banks, investment firms and asset managers.
In Ireland the head of compliance and the head of anti-money laundering and counter terrorist financing compliance are pre-approval controlled functions (PCFs). Nobody can start in either role until the Central Bank has approved them, through an individual questionnaire and, for some roles, an interview. A shortlist that cannot evidence fitness and probity costs a firm months, and a vacant control function is a supervisory issue in its own right.
The bar keeps rising. The Conduct Standards and enhanced fitness and probity standards under the Individual Accountability Framework applied from 29 December 2023, and the Senior Executive Accountability Regime (SEAR) has applied to executive PCFs at in-scope firms since 1 July 2024. The workload has grown too: DORA has applied across the EU since January 2025, the AIFMD II and UCITS amendments had to be transposed by 16 April 2026 with reporting changes due from 16 April 2027, and Head of Safeguarding became a PCF for payment and e-money institutions on 10 February 2026. In our payments work, the Head of Compliance and the AML lead are often the hardest pair of roles to fill well in Ireland.
How we run a compliance search
We map who has held the role. We track the leadership of Irish fund services firms, CBI authorised payments firms and the Irish entities of international groups, so we know who has already held a compliance or AML PCF, who has taken a firm through authorisation and who is open to a move.
We test for approvability early. Candidates are assessed against fitness and probity expectations before they reach your shortlist, not after an offer is made.
We plan around notice and approval. Notice periods for senior roles are commonly three to six months, and the Central Bank approval step sits on top of that. Both are built into the search plan from day one, so your start date is realistic.
We check for substance. The Central Bank expects real decision making in Ireland. We look for compliance leaders who will run the function from here, not sign off decisions made elsewhere.
We look at the whole team. A Head of Compliance hire changes the dynamic with the CEO, the Chief Risk Officer and the board. We assess fit with the people the new leader will work alongside.
Compliance and AML roles we search for
- Heads of Compliance and Chief Compliance Officers
- MLROs and Heads of AML and counter terrorist financing compliance
- Heads of Safeguarding at payment and e-money institutions
- Chief Risk Officers and Heads of Risk
- Heads of Internal Audit
- Heads of Legal and General Counsel (see legal executive search)
- Independent non-executive directors with risk, audit and regulatory backgrounds
Recent work: an independent investment manager had struggled to find a Head of Compliance with strong knowledge of a broad range of funds who could move at speed. After research across the European market, we presented head of function profiles from proprietary and third party fund managers familiar with the Central Bank of Ireland.
Who we work with: fund administrators, depositaries and fund management companies (see fund administration executive search); payment institutions, e-money institutions and crypto asset service providers (see payments and fintech executive search); and banks, investment firms and asset managers building or strengthening their Irish entity.
Head of Compliance and MLRO searches sit within our risk and compliance practice. For every role that needs Central Bank approval, from CEO to board, see PCF executive search in Ireland. For compliance leaders under the CSSF, see fund services executive search in Luxembourg.
Further reading: AIFMD II and UCITS amendments: key milestones and leadership readiness and Building Your C-Suite in Payments: Ireland, UK and US.
Frequently asked questions
Is the Head of Compliance a PCF role in Ireland?
Yes. At firms regulated by the Central Bank of Ireland, the head of compliance and the head of anti-money laundering and counter terrorist financing compliance are pre-approval controlled functions, alongside directors, the CEO and the heads of finance, risk and internal audit. Check the current PCF list against your own business model before writing the brief, as the list changes.
How long does a Head of Compliance or MLRO search take?
The timeline is driven mostly by notice and approval. Notice periods for senior roles are commonly three to six months, and a candidate cannot start in a PCF role until the Central Bank has approved them. We build both into the plan from the first week.
Can you help a firm going through Central Bank authorisation?
Yes. Applicants need credible, approvable people in key PCF roles, including compliance and AML, before authorisation is granted. We help firms identify and secure those leaders early in the application.
Does SEAR apply to compliance leaders?
SEAR currently applies to in-scope firms such as banks, most insurers and certain investment firms, and it does not yet cover payment and e-money institutions. The Conduct Standards and the fitness and probity regime apply to PCF holders across all regulated firms, and good candidates will ask how their responsibilities are documented.
Do you search for compliance leaders outside Ireland?
Yes. Our risk and compliance practice covers Ireland, the UK and the US, and we run senior regulated searches for fund services firms in Luxembourg.
