I've been speaking with a client this week who's currently in a really exciting stage of growth for their compliance function.

They’ve already built a well-established onboarding team, but now, the challenge is: how do you take this to the next level? How do you structure a compliance team that can scale as the firm grows, whilst still giving your people real opportunities to progress?

We’ve been talking about what an effective compliance and onboarding team actually looks like. How do you structure roles so progression makes sense, without titles feeling arbitrary or performative?

What does Compliance Onboarding Typically Involve?

• Anti-Money Laundering (AML)
• Client Due Diligence (CDD)
• Conflicts of Interest

One of the most important questions in building your team is when to split onboarding into sub-functions. This typically becomes necessary when the complexity or volume of your work changes.

Take this example: I’ve recently been working with a client who expanded significantly in the US. Given the intensity of the conflict checks needed for this work, the onboarding team was drowning.

So rather than add more people into a generalist end-to-end onboarding role, we built out a dedicated conflicts function that will continue to withstand the volume and complexity of conflicts checks coming from the US.

Splitting the functions isn’t just about efficiency, it enables more focused, consistent responses to regulators and internal queries.

Compliance Team Structure (Onboarding, AML & Conflicts)

🔹 Entry Level Role: Compliance Assistant / Compliance Administrator

Aka - Business Intake Assistant or Onboarding Assistant

Responsibilities:

• Administrative support (data entry, client/matter opening)
• Initial documentation gathering for KYC/AML
• Assisting analysts with background checks and conflict screens

🔹 Junior-Level  Analyst: Compliance Analyst

Also commonly split into AML Analyst or Conflicts Analyst

Responsibilities:

• Conducts detailed client due diligence and conflict checks
• Reviews sanctions lists, beneficial ownership, risk scoring
• Liaises with legal teams to resolve flags or issues
• May begin drafting recommendations for approvals

🔹 Mid-Level: Senior Compliance Analyst

Again, commonly split into Senior Conflicts Analyst or Senior AML Analyst

Responsibilities:

• Handles complex or high-risk matters
• Mentors and reviews work of junior analysts
• Escalates issues to compliance managers or lawyers
• Leads on policy implementation and workflow improvements

🔹Management/Specialist Roles:

Compliance Officer (or split across conflicts/AML)

Conflicts Manager / AML Manager

Risk and Compliance Manager

Responsibilities:

• Oversees day-to-day operations of a team (conflicts or AML)
• Provides technical advice on complex regulatory matters
• Ensures team performance, compliance with SLAs
• Involved in training, internal audits, reporting

🔹 Senior Management /Advisory

Compliance Advisor (can be split across Conflicts / AML)

Head of Conflicts / Head of AML

Head of Client Acceptance

Director of Business Intake

Responsibilities:

• Strategic leadership across all compliance functions
• Sets and enforces firm-wide compliance policy
• Liaises with regulators, leads on global projects and audits
• Advises partnership on high-risk matters and ethical conflicts
• Often reports directly to the Chief Risk Officer or Managing Partner

If you’re looking at a career path, Assistant to Advisor can take 7-10 years depending on the firm size, specialisation and performance.

Firm Examples:

Clifford Chance:

Structure & Progression:

• Compliance Assistant / Business Intake Administrator
• Conflicts Analyst / AML Analyst
• Senior Conflicts Analyst / AML Senior Specialist
• Compliance Officer / Risk & Compliance Manager
• Head of Business Acceptance / Global Head of Risk

Key Distinctions:

• Clifford Chance splits AML and conflicts into separate teams, even in their regional hubs like Warsaw or Newcastle.
• They have a central Risk and Compliance team reporting into a Global General Counsel.
• Their London team is the global HQ for compliance strategy.

Linklaters:

Structure & Progression:

• Intake Administrator
• Client Due Diligence Analyst (CDD)
• Conflicts Analyst
• Compliance Officer / Intake Manager
• Head of Risk and Resilience / Chief Risk Officer

Key Distinctions:

• Linklaters structures its onboarding under the broader umbrella of Risk & Resilience.
• Maintains distinct AML and Conflicts divisions, but encourages cross-training.
• Offices like Lisbon and Manchester serve as compliance processing hubs.

When Should You Split AML and Conflicts?

There’s no one-size-fits-all moment, but there are red flags that tell you your team has outgrown the “all-in-one” approach. Sometimes it’s a spike in client intake. Other times, it’s a shift in the type of work you're doing, just like a move into new jurisdictions like the US we mentioned above, where conflict checks are intense and highly time-sensitive.

I’ve seen firms try to stretch a single onboarding team across everything, from KYC to conflict resolution, and it works… until it doesn’t. Eventually, you hit a tipping point. The demands diverge. The processes get too specialised. And the team starts spending more time switching between areas than doing the actual work.

That’s when it makes sense to split. Dedicated AML and Conflicts teams aren’t just about efficiency, they’re about resilience. With defined ownership and focus, teams can go deeper into their subject matter, respond faster to risk, and build real confidence across the firm.

Final Thoughts

Building a well-structured team and giving your compliance professionals the chance to genuinely progress is one of the most effective ways to retain talent and strengthen your firm’s compliance culture.

When people know there’s a clear path ahead and that their roles aren’t just placeholders, they become more invested. That energy filters out into the wider business, helping embed compliance into how the firm thinks and operates.

Whether you’re just starting to build out a team, or scaling an existing one into global maturity, getting the structure right is where it all begins.

If you’re looking to expand your team and need some advice and support in how to grow effectively. Reach out Lauren.Eager@QEDLegal.com