FRACTIONAL AML, COMPLIANCE & TECHNOLOGY LEADERSHIP
Senior expertise. Ongoing involvement. Flexible capacity.
Embedded executive and audit leadership for organizations that need continuity, judgment and hands-on implementation—without adding a full-time role.
MORE THAN PROJECT ADVICE
A fractional engagement gives an organization access to experienced leadership for a defined portion of time and a defined set of outcomes. The work is ongoing and embedded: setting priorities, participating in decisions, guiding teams, reviewing evidence and helping move the program forward.
It can bridge a leadership transition, add capability during a demanding period or give a growing organization senior expertise before a permanent role makes sense. Fractional describes how ICRM engages; the work remains grounded in ICRM’s AML, sanctions, internal audit, compliance technology and implementation experience.
POTENTIAL ROLES
One role, a blended mandate or a defined transition.
Scope follows the organization’s responsibilities and risks.
Provide senior direction across AML/CFT, sanctions, customer risk, screening, monitoring, governance and program improvement—while helping the existing team turn priorities into operating practice.
Provide continuity and accountable leadership during growth, transition or a search for a permanent executive. Any formal officer appointment is scoped case by case around authority, access, resources and reporting lines.
Connect regulatory expectations and practitioner needs with product direction, consultative sales, implementation and client outcomes for financial-crime and compliance technology providers.
Help directors oversee regulatory remediation and challenge management constructively. Translate complex findings and plans into clear milestones, evidence expectations, dependencies and decisions for the Board.
Provide experienced leadership for compliance internal audit, AML and sanctions audit programs—from risk assessment and audit planning through detailed control evaluation, issue reporting and follow-through.
WHY ICRM
Steve combines institutional leadership, consulting, internal audit and compliance-technology experience. The result is a practical view of what regulators, directors and executives expect—and the detailed discipline needed to show that controls work.
C-suite experience as a Chief Risk Officer and Chief Compliance Officer, with responsibility to management, regulators, Board committees and directors.
Extensive internal-audit experience, including many AML and sanctions audits and detailed evaluation of control design, operation, evidence and sustainability.
A rigorous risk and control matrix connects obligations to risks, control objectives, accountable controls, evidence, testing, findings and remediation.
Experience connecting regulatory intent with data, screening, risk engines, workflow, product direction, implementation and client outcomes.
Clear reporting helps directors distinguish activity from effective, sustainable remediation and direct their challenge to the issues that matter.
Steve is directly involved in the work, with an explicit mandate to strengthen the organization’s own people, processes, controls and governance.
THE RISK & CONTROL MATRIX DISCIPLINE
Steve’s internal-audit background shapes the fractional offer. The question is not simply whether a policy exists; it is whether each relevant requirement has been translated into an understood risk, an effective control, a clear owner and evidence that can withstand testing and challenge.
BOARD ADVISORY / REMEDIATION OVERSIGHT
For boards overseeing remediation arising from enforcement actions, regulatory examinations, internal audit, independent testing, model validation or significant system issues.
Connect each finding and commitment to accountable actions, milestones, dependencies and closure criteria.
Help directors ask focused questions about progress, root cause, evidence quality, residual risk and obstacles.
Build concise reporting that distinguishes activity from sustainable remediation and supports timely Board decisions.
The Board oversees and challenges; management executes. ICRM’s role is advisory and is defined to preserve that distinction, along with any required independence from testing, validation or assurance work.
WHEN IT FITS
HOW AN ENGAGEMENT WORKS
Clarify the outcomes, authority, responsibilities, stakeholders, reporting line and boundaries of the role.
Reserve capacity through an initial three- or six-month term, with regular leadership sessions, working meetings and progress reporting.
Participate in decisions, guide implementation, review evidence and adapt the plan as risks and facts change.
Review the mandate periodically, renew where useful and transfer responsibilities deliberately when the need changes.
THE FIRST 30 DAYS
Document the mandate, decision rights, access, resources, reporting lines and independence safeguards.
Assess risk assessments, examinations, audits, enforcement commitments, policies, systems, data and current reporting.
Build or refresh the risk and control matrix, including ownership, evidence, testing results, gaps and open remediation.
Set immediate priorities, a 90-day plan, success measures and a practical management and Board reporting cadence.
ACCOUNTABILITY & INDEPENDENCE
A formal Compliance Officer, AML Compliance Officer or similar appointment would be considered only where the organization provides appropriate authority, resources, information access, escalation rights and direct access to senior management and the Board. The institution retains its legal and regulatory responsibilities.
Management leadership, Board advice, remediation support, independent testing, validation and internal audit are distinct roles. ICRM scopes them separately, does not independently validate work it designed or implemented, and does not present implementation support as audit assurance.
EXPERIENCE BEHIND THE OFFER
Steve brings four decades of experience across financial institutions, consulting, internal audit and compliance technology. His financial-institution experience includes C-suite service as a Chief Risk Officer and Chief Compliance Officer, with responsibility for enterprise risk and compliance programs, executive decision-making, regulatory relationships, Board and committee reporting, and advising directors on significant risks, issues and remediation.
His internal-audit work includes numerous AML and sanctions audits and detailed risk and control matrices that match regulatory requirements with risks, controls, accountable owners, evidence and testing. That combination matters in a fractional role: Steve understands the responsibilities carried by management, the information and challenge a Board or Audit Committee needs, and the assurance discipline required to evaluate whether controls are designed and operating effectively.
Examples of embedded and advisory leadership include:
Earlier in his career, Steve served in an embedded contract compliance officer capacity for a new and rapidly growing bank, providing continuing compliance leadership during a period of significant expansion.
He later led an embedded advisory-services function for a financial-crime technology provider, connecting regulatory interpretation, product development, consultative sales, client delivery and industry education.
FREQUENTLY ASKED QUESTIONS
A fractional leader provides experienced executive capacity for an agreed portion of time and a defined mandate. Unlike a short advisory project, the role is embedded in the organization’s working rhythm and may include decisions, team guidance, governance, Board reporting and sustained follow-through.
A consulting project usually produces a defined analysis or deliverable. Fractional leadership adds continuing ownership and involvement: setting priorities, participating in decisions, guiding implementation, reviewing evidence and helping the organization adapt as facts and risks change.
The model can fit a leadership transition, a period of rapid growth, a demanding remediation agenda or a continuing need that does not yet justify a full-time executive. It can also help an organization define a permanent role and transfer responsibilities deliberately when the time is right.
A formal officer appointment would be considered case by case and only when the organization provides appropriate authority, resources, information access, escalation rights and direct access to senior management and the Board. The institution retains its legal and regulatory responsibilities.
The written mandate identifies responsibilities, decision rights, reporting lines and working cadence. Steve works through the existing organization, clarifies ownership and helps teams connect regulatory requirements, risks, controls, data, technology and evidence without displacing accountable management.
Yes. Support can include translating findings and commitments into accountable actions, milestones, dependencies, evidence standards, closure criteria and Board reporting. The scope distinguishes management execution, Board oversight and any independent validation or assurance.
Management leadership, remediation advice and independent assurance are distinct roles. ICRM defines the role and safeguards in writing, does not independently validate work it designed or implemented, and will not characterize advisory support as audit assurance.
The initial period confirms the mandate and boundaries, reviews the most important risk and regulatory information, maps requirements to risks and controls, identifies immediate priorities and agrees a practical 90-day plan and reporting cadence.
The organization and ICRM agree the required outcomes, reserved capacity, meeting and reporting rhythm, access and responsibilities in a written scope. An initial three- or six-month term is common. Fees reflect the mandate and capacity rather than a generic subscription package.
A full-time hire may be more appropriate when daily decision volume requires continuous presence. ICRM also will not accept a mandate without sufficient authority, access and resources, or combine management and assurance responsibilities in a way that compromises independence.
START WITH THE MANDATE
Talk with Steve about the situation, the responsibilities involved and the result the organization needs. If fractional leadership is not the right structure, ICRM can help identify a more suitable advisory scope.
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