Stephen Frame

Immediately deployable senior risk, compliance and financial crime executive with 15+ years' leadership experience across payments, FinTech, electronic money and FX in the UK and Europe. FCA and BaFin approved, with appointments spanning Chief Compliance Officer, MLRO, Chief Risk Officer, SMF16/SMF17 and BaFin Managing Director. Combines board-level judgement with a pragmatic, hands-on approach to regulatory change, AML/CTF, safeguarding, operational resilience and enterprise risk.

Works closely with product, commercial and engineering teams to turn regulatory requirements into viable customer journeys, operating models and routes to market. Experienced in stepping into complex or under-resourced environments, establishing priorities quickly and enabling controlled growth. Open to interim, fractional and permanent mandates.

Chief Compliance Officer & MLRO at Midpoint & Transfer Ltd. (2025-06 – Present)

FCA-regulated payments and remittance business

• Lead the enterprise risk, compliance and AML/CTF framework, aligning governance, policies, controls and monitoring with FCA expectations.
• Advise the Board on regulatory change, material compliance risks, control effectiveness and strategic decisions, including Change in Control.
• Completed the FCA Change in Control process following the firm's acquisition, coordinating regulatory submissions and stakeholder engagement.
• Partner with product, commercial and engineering stakeholders on card products and stablecoin and crypto payment flows, designing compliant operating models that support viable routes to market.
• Define the regulatory perimeter, customer and merchant journeys, flow of funds, partner responsibilities and proportionate financial crime controls for new propositions.

Head of Compliance & MLRO (Interim) at Apex Currency Ltd. (2025-04 – 2025-06)

Foreign exchange business covering spot and forward products

• Set the compliance strategy for FX operations, safeguarding, customer risk and regulatory engagement during an interim leadership assignment.
• Strengthened financial crime governance, transaction monitoring, regulatory reporting and the integration of Consumer Duty into product and service oversight.

Chief Risk & Compliance Officer at Tuum (2024-09 – 2025-03)

Banking technology and FinTech platform

• Served on the Management Board and designed the enterprise risk framework across operational, strategic, financial and technology risk.
• Directed operational resilience, impact tolerances, business continuity and third-party dependency management.
• Led compliance monitoring, regulatory engagement and readiness for DORA and evolving UK conduct requirements.

Chief Compliance Officer & MLRO at Caxton Payments Ltd. (2022-11 – 2024-08)

FCA-regulated electronic money and payments business

• Held SMF16, SMF17 and EMD responsibilities, providing senior oversight of compliance, financial crime and regulatory reporting.
• Led safeguarding, AML/CTF strategy, compliance monitoring and internal investigations across the regulated business.
• Enhanced financial crime capability and training, and implemented APP fraud policies, procedures and frontline guidance.

Group Head of Risk, Security & Compliance / MLRO at Token.io Ltd. (2018-01 – 2022-10)

Open banking payments platform operating in the UK and Europe

• Management Board member and BaFin-approved Managing Director for the German entity, with oversight across UK and German operations.
• Led compliance with PSD2, GDPR, ISO 27001 and financial crime requirements, alongside regulatory engagement and security governance.
• Built and developed UK and German financial crime teams, including DMLRO capability, and strengthened policy, monitoring and escalation arrangements.
• Enabled growth through compliance due diligence on strategic partnerships, acquisitions and new product launches.

Director at Sensu360 Ltd. (2017-04 – 2018-01)

Head of Business Controls & MLRO at Selfridges & Co. (2013-06 – 2017-04)

Head of Loss & Safety at River Island Clothing Co. (2007-09 – 2013-07)

Head of Profit Protection at Sainsbury's Supermarkets (2006 – 2007)

Head of Profit Protection at Marks & Spencer plc (2002 – 2006)

HND in Business Studies – Napier University