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Section 250 map for payments MLROs

An MLRO or financial-crime lead in a payments firm may require s.250(3) review where their authority affects onboarding controls, transaction monitoring, escalation, or the management of financial-crime risk across a substantial part of the organisation. This page is a thin-data pilot, not a measured market benchmark.

Functional-test signals

These signals are prompts for review. They do not decide the legal answer; they show what a compliance team should evidence when assessing whether the role plays a significant role in managing or organising the firm.

Authority over AML, sanctions, fraud, onboarding, or transaction-monitoring controls used across material payment flows.

Power to approve financial-crime policies, escalation thresholds, or remediation plans relied on by operational teams.

Responsibility for suspicious-activity escalation, regulator reporting inputs, or board-level financial-crime reporting.

Participation in governance forums where financial-crime decisions shape how the firm is managed or organised.

Evidence to collect

  1. Record the financial-crime responsibilities being assessed under the s.250(3) functional test.
  2. Cross-reference the role against SM&CR records, MLRO appointment evidence, policy ownership, and committee terms.
  3. Document why the role is included, excluded, or flagged for legal review.
  4. Attach the conclusion to the governance evidence pack and renewal cadence.

Asset-backed coverage context

These aggregate values come from the latest coverage asset rows. They describe source-role coverage quality only; they do not decide whether mlro / financial crime lead in payments satisfies the statutory test.

Sample firms in latest coverage asset

3

Source roles in latest coverage asset

33

SMF holders in latest coverage asset

33

Unresolved source roles in latest coverage asset

0

Source date2026-05-19
Methodologycoverage-derivation-v1
Output hasha5dae2ee03f9

Asset-derived source-role context only; not a Section 250 exposure determination.

Caveats

  • The s.250 test is functional, not title-based. A job title alone is not enough.
  • SM&CR is a useful baseline, not the statutory boundary.
  • Section 250 is corporate attribution, not a failure-to-prevent offence.
  • This page is general information and not legal advice on any specific role.

No benchmark count is claimed on this pilot page. The page uses a thin data stub until Phase 2 supplies a measured FCA-register and coverage dataset.

Sources