How to Hire a Head of Compliance for a Crypto Licence

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Hiring a Head of Compliance for a Crypto Company Applying for a Licence

Last updated: 10 November 2026

Key takeaways

At application stage the Head of Compliance writes or owns the documents the regulator reviews, so the hire shapes the application itself.
The strongest signal is experience of a successful licence or registration application for a similar business.
The FCA expects an AML framework tailored to the business model, not generic, off-the-shelf or high level.
Test crypto-specific knowledge: the travel rule, wallet screening and market abuse, which MiCA Article 92 addresses for anyone arranging or executing crypto transactions.
Start the search early: senior compliance candidates often have long notice periods.

If you need to hire head of compliance crypto talent for a licence application, hire before you draft, not after. At this stage the Head of Compliance writes or owns the policies, procedures and risk assessments the regulator will read, and in many cases answers the regulator's questions about them. A strong candidate makes the application credible; a weak one makes it generic.

This guide is for founders and COOs of crypto and blockchain companies preparing a licence or registration. It covers the profile to look for, the crypto-specific knowledge to test, the red flags and the timing.

Why the application stage needs a different profile

A Head of Compliance in an established, licensed firm usually runs a framework that already exists. At application stage there is no framework yet. The person has to:

Build the compliance and AML framework from scratch for your exact business model.
Write or own the policies, procedures and business risk assessment.
Choose and configure monitoring and screening tools, and explain those choices.
Deal with the regulator directly, often through rounds of questions.

The FCA's guidance for cryptoasset applicants shows what that means in practice. It describes a good application as one where documents are tailored to the business model and bespoke to the firm, where the AML framework is not generic, off-the-shelf or high level, and where tools are configured for the firm's own risks rather than used "out of the box". That is the work your Head of Compliance will do.

	Application stage	After the licence
Main task	Build the framework and write the documents the regulator reviews	Run, test and improve the framework
Regulator contact	Answering questions on the application, sometimes interviews	Reporting, inspections, ongoing supervision
Team	Often alone or with one analyst	Growing team, delegation
Strongest signal	A successful application for a similar business	Experience running compliance at your scale
Main risk if mismatched	Generic documents and a slow or failed application	A framework that does not keep up with growth

The profile to look for

A successful application for a similar business. This is the strongest signal. Ask which regulator, which business model, what the candidate personally wrote and how the questions from the regulator were resolved.

Direct regulator experience. Meetings, information requests, interviews or inspections the candidate handled personally, not ones their manager handled.

Building from scratch. Evidence they have created a framework, not only maintained one: the first AML policy, the first risk assessment, the first monitoring set-up.

Crypto-specific risk knowledge. The candidate should talk about crypto risks in specific terms:

The travel rule. Information about the originator and beneficiary must accompany crypto-asset transfers between service providers. In the EU this applies under Regulation (EU) 2023/1113 from 30 December 2024; in the UK it sits in Part 7A of the Money Laundering Regulations 2017.
Wallet screening and blockchain analytics. How they would assess the risk of the addresses customers send to and receive from.
Market abuse. Under MiCA Article 92, any person professionally arranging or executing transactions in crypto-assets must have effective arrangements, systems and procedures to prevent and detect market abuse, and must report reasonable suspicions without delay to the competent authority.

If the Head of Compliance will also be your MLRO, check the regulator allows it and see How to Hire an MLRO for a Crypto or Fintech Company.

Applying for a crypto licence and still need a Head of Compliance?

Send us the job description and your target regulator, and we will look for candidates who have taken a crypto firm through a similar application.

Send us the job description

Regulator conditions on the role

Some regulators set conditions on the compliance role itself. VARA in Dubai, for example, requires a Compliance Officer who has at least five years of relevant experience in a compliance function, is fit and proper as approved by VARA, is resident in the UAE or holds a UAE passport, is a full-time employee and reports directly to the board. A strong candidate who cannot meet the residence condition in time will not help the application.

Other regulators assess the person through their fit and proper process. For what that involves, see Key Function Holders: What Regulators Check Before Approving a Hire.

Questions to ask when you hire head of compliance crypto candidates

Use questions that make the candidate apply their experience to your business:

"Walk me through the last application you worked on. Which documents did you write yourself, and what did the regulator ask about them?"
"Our customers will send and receive crypto from external wallets. How would you screen those addresses, and what would make you block a transfer?"
"How would you meet the travel rule for transfers to a service provider that does not support it?"
"What would your market abuse monitoring look like in our first year, and who would review the alerts?"
"Which parts of a template AML policy would you throw away for our business, and why?"

Strong answers name tools, decisions and trade-offs. Weak answers repeat general principles.

Red flags

Only large-bank experience with existing frameworks. Not disqualifying, but ask what they built themselves and how they would work without a large team.
Generic AML language. If the candidate cannot explain crypto risks without falling back on general AML terms, the documents they write will read the same way, and regulators notice.
No application experience at all. A good operator of a licensed firm may still struggle with a first application.
A CV that does not survive a fit and proper review. Unexplained gaps, short roles at firms that lost licences, or too many other appointments.

Timing

Start the search before the application is drafted. Senior compliance people often have long notice periods, and a late search pushes back the submission. If you need someone to start the work while the permanent search runs, read Interim vs Permanent Compliance Hires: When Each Makes Sense first, because some regulators expect the permanent person to be named in the application.

What we recommend

Decide the regulator and the business model first, and write the job description around them.
Shortlist candidates with a successful application for a similar business and direct regulator experience.
Test crypto-specific knowledge in the interview: the travel rule, wallet screening and market abuse, applied to your products.
Check the regulator's conditions on the role, such as residence, full-time employment and experience.
Start the search before drafting begins, and plan around the candidate's notice period.

FAQ

What does a Head of Compliance do during a crypto licence application?

At application stage the Head of Compliance writes or owns the policies and procedures the regulator reviews, builds the compliance and AML framework, and often answers the regulator's questions. The FCA, for example, expects an AML framework tailored to the business model rather than generic, off-the-shelf or high level.

What experience should a crypto Head of Compliance have?

The strongest signal is experience of a successful licence or registration application for a similar business. Look also for direct dealings with a regulator, experience building a framework from scratch, and a working understanding of crypto-specific risks such as the travel rule, wallet screening and market abuse.

Is a compliance officer from a bank a good fit for a crypto start-up?

Sometimes, but large-bank experience alone is a red flag for an application-stage role. Bank compliance officers often maintain existing frameworks with large teams, while a crypto applicant needs someone who can build one and explain crypto risks in specific terms rather than generic AML language.

What is the travel rule for crypto firms?

The travel rule requires information about the originator and beneficiary to accompany crypto-asset transfers between service providers. In the EU it applies under Regulation (EU) 2023/1113 from 30 December 2024, and in the UK under Part 7A of the Money Laundering Regulations 2017.

What does MiCA require on market abuse?

Under MiCA Article 92, any person professionally arranging or executing transactions in crypto-assets must have effective arrangements, systems and procedures to prevent and detect market abuse, and must report reasonable suspicions without delay to the competent authority.

Does VARA set requirements for a crypto Compliance Officer?

Yes. VARA's Compliance and Risk Management Rulebook requires a Compliance Officer with at least five years of relevant experience in a compliance function, who is fit and proper as approved by VARA, resident in the UAE or a UAE passport holder, a full-time employee and reports directly to the board.

When should a crypto company start searching for a Head of Compliance?

Before the application is drafted. The person should write or own the policies the regulator will review, and senior compliance candidates often have long notice periods, so a late search can delay the submission.

The bottom line

To hire head of compliance crypto talent for a licence, look for someone who has done it before: built a framework from scratch, written documents a regulator accepted and can explain crypto risks in specific terms. Hire them before the drafting starts. Hirexel recruits Heads of Compliance and compliance teams for crypto, blockchain and fintech firms preparing licence applications, and screens candidates on application experience and regulator fit.

Planning your compliance hire for a licence?

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