The Foreign Exchange and Payments sectors are experiencing one of the most demanding regulatory periods in recent memory. For leaders responsible for compliance and financial crime functions, this translates directly into increased pressure on headcount, specialist capability, and operational resilience.
At Coopman Search & Selection, we work closely with firms navigating these pressures. As firms scale, compete, and adapt to new rules, many are reassessing the skills they need to remain compliant, resilient, and commercially agile right now and going into 2026.
Regulatory Pressures Shaping Demand
Financial Crime & Fraud Prevention
The introduction of the Failure to Prevent Fraud (FTPF) offence is reshaping expectations around fraud risk management. FTPF requires firms to have “reasonable procedures” to prevent fraud committed by employees, agents, or those working on their behalf.
Based on available data:
- 72% of Payments/FX firms report they have updated fraud risk assessments in the last 12 months.
- 49% say FTPF has increased expected headcount within the next year.
Already we’ve seen a sharp increase in demand for specialist in this area, with the following roles being some of the notable movers:
- Fraud Framework Leads (+34% YoY)
- Fraud Strategy/Data Analysts (+29% YoY)
- Financial Crime Advisory (Fraud Integration) (+22% YoY)
Safeguarding & Prudential Expectations – CASS 15
The FCA’s CASS 15 regime for payment services is a major development aimed at ensuring proper safeguarding of customer funds. This has led to a huge numbers of firms needing to upgrade safeguarding reconciliation requirements, documenting risk frameworks around operational and liquidity risk and introducing more robust governance reporting and senior manager accountability.
Since the finalisation of this:
- Approximately 63% of EMIs/PIs have initiated safeguarding framework upgrades
- 41% of firms experienced regulatory queries linked to safeguarding in the last year
- 1 in 5 firms surveyed indicated that CASS/safeguarding gaps were a high or critical risk on board MI
The supply of CASS SMEs remains extremely low, with reports suggesting that for every ten open roles, there are approximately three suitable candidates available. The in demand areas of focus are
- Head of CASS/ Safeguarding (+38% YoY)
- Prudential Risk & Liquidity Analysts (+19% YoY)
- Operational Finance/Reconciliation experts (+25% YoY)
These shortages have driven up the market value of those candidates with SMF16/17, or equivalent, experience who are confident in navigating early-stage/scaling firms with the development of safeguarding frameworks, as well as the provision of regulatory and anti-financial crime advice.
What Firms Can Do To Be More Proactive in Securing Top Talent
Strengthen Your Employer Proposition
- Provide clear career progression—this is a major differentiator against banks and investment firms
- Highlight flexible working, which remains a top priority in the sector
- Offer visibility and influence for technical experts, not just senior leaders
- Demonstrate commitment to regulatory maturity; candidates avoid firms with chaotic compliance
Be Strategic About Hiring Ahead of Regulation
Instead of reactive hiring during regulatory pressure:
- Build talent pipelines for CASS, safeguarding, and fraud roles
- Consider interim specialists during remediation or regulatory change
- Invest in internal upskilling, especially in CASS and fraud frameworks- over a third of firms have begun cross-training staff in CASS, Fraud, or AML to compensate for shortages.
Improve the Speed & Structure of Hiring Processes
Top compliance and risk candidates move fast; firms should:
- Avoid long interview chains or vague role scopes- firms with <3 interview stages fill roles 40% faster.
- Provide clear feedback loops
- Use practical assessments only where they add value- dropping “assignment-based” tasks reduces candidate fallout by 30%
Conclusion & Outlook for 2026 – What the Data Suggests
Based on current hiring, regulatory and market behaviour regulatory headcount demand in Payments/FX is expected to grow another 12–18% next year, with FTPF and CASS being two of the largest driving forces behind this. As always, firms with strong governance and resilience maturity will remain more attractive to senior talent which can be the real differentiator when looking to hire specialist roles across compliance which do come with a limited market supply.
