Interim compliance officer: tasks, requirements and engagement models
Discuss your needsShort answer: An interim compliance officer covers a vacancy or strengthens the compliance function for a project: assessing compliance risk, updating directives, handling anti-money laundering cases, training staff and reporting to senior management and the board. In Switzerland, banks need an independent compliance function with an annual risk assessment and annual reporting (FINMA Circular 2017/1, margin nos. 77–81); in Germany, a compliance function that reports to management at least once a year (MaRisk AT 4.4.2). The role is filled on an interim basis through staff leasing or freelancing, part-time or full-time.
This guide is for senior management, chief risk officers, heads of compliance and HR leads in banks, wealth managers, insurers and industrial companies in Switzerland and Germany. It sets out what an interim compliance officer does, the supervisory framework in both countries, the profile you should look for and the two engagement models.
Tasks by type of organisation: bank, wealth manager, insurer, industry
A compliance officer's tasks depend mainly on whether and how the organisation is supervised. The table shows typical tasks and matching interim roles; it applies equally to Switzerland and Germany.
| Type of organisation | Typical compliance tasks | Interim role |
|---|---|---|
| Bank, investment firm | Annual compliance risk assessment, activity plan, reports to senior management and the board, AML, transaction monitoring, KYC, sanctions, financial market rules | Interim head of compliance, compliance officer, MLRO or Swiss AML function, KYC and AML analysts |
| Wealth manager, payment or financial services institution | AML, client files, risk analysis, directives, conduct rules towards clients | Part-time compliance officer, project for directives and risk analysis |
| Insurer | Compliance function, distribution and product rules, governance, AML in life insurance | Compliance officer, regulatory project support, AML specialist |
| Industry, trade, technology | Code of conduct, sanctions and export control, anti-bribery, competition law, data protection, whistleblowing system, training | Interim compliance manager, compliance management system project lead, subject matter experts |
Industrial companies are under no supervisory obligation to run a compliance function. The drivers there are sanctions, international customers, requirements from business partners and management's duty to organise the business properly. How to set up a compliance management system is explained in our guide to building a compliance management system.
Supervisory framework: FINMA and BaFin compared
For financial institutions, both supervisors require an independent compliance function and a dedicated anti-money laundering function, but the rules differ in detail. The table compares the key provisions.
| Topic | Switzerland (FINMA) | Germany (BaFin) |
|---|---|---|
| Compliance function in banks | Independent control functions covering risk control and compliance; institutions in supervisory categories 1–3 need a separate compliance function (FINMA Circular 2017/1, margin nos. 62–81, in particular no. 67) | Every institution needs a compliance function that generally reports directly to management and sits outside the front office; a compliance officer must be appointed (MaRisk AT 4.4.2) |
| Minimum tasks and reporting | Annual compliance risk assessment with an activity plan approved by senior management; annual report to the board; timely reporting of serious breaches (FINMA Circular 2017/1, margin nos. 77–81) | Report to management at least annually and when needed, passed on to the supervisory board and internal audit; the supervisory board must be informed in advance when the compliance officer changes (MaRisk AT 4.4.2) |
| Insurers | FINMA Circular 2017/2 "Corporate governance – insurers" | Internal control system with a compliance function (section 29(1) of the Insurance Supervision Act, VAG) |
| Anti-money laundering | AML unit (Geldwäschereifachstelle) of one or more qualified persons; external persons only if an internal unit is not possible or disproportionate given size or organisation (Art. 24 and 25(4) GwV-FINMA) | Money laundering reporting officer at management level plus a deputy; appointment to be notified in advance, in BaFin practice at least two weeks before (section 7(1) and (4) GwG) |
| Outsourcing | Operational compliance tasks may be outsourced, but not ultimate direction or strategic decisions (FINMA Circular 2018/3) | Full outsourcing of the compliance function only for very small institutions (MaRisk AT 9); outsourcing rules in section 25b of the Banking Act (KWG) |
A specialist on staff leasing works integrated into the institution's organisation and under its instructions. In Switzerland this is generally not outsourcing: outsourcing under FINMA Circular 2018/3 requires a provider to perform a material function independently and on a lasting basis, whereas under Personalverleih (Swiss staff leasing) the right to give instructions lies with the client (Art. 26 of the Recruitment Ordinance, AVV). In Germany, the institution assesses and documents whether an engagement is outsourcing under MaRisk AT 9; this applies to staff leasing as well as to a freelance mandate or the award of a work package.
Profile and experience
An interim compliance officer must work independently from day one. Experience in the same type of organisation and knowledge of the rules in the relevant country are therefore decisive.
- Education: law, economics or banking, often with further training in compliance or AML.
- Rulebooks: in Switzerland the GwG, GwV-FINMA, the banks' due diligence agreement (CDB, German: VSB) and FINMA circulars; in Germany the GwG, KWG, MaRisk and BaFin's interpretive guidance.
- Experience: same type of organisation and client segment, for example private banking, retail, wealth management or life insurance.
- Leadership and reporting: for leadership roles, experience reporting to senior management, the board, the audit firm and the supervisor.
- Languages: depend on the client base and working environment. State in the role profile which languages are needed to negotiation level and which only for reading.
- Integrity: clean record and no conflicts of interest with clients or business units.
Seniority follows the role: senior for interim leadership and formal functions, experienced for day-to-day compliance work, junior for analysis within a team.
Staff leasing or freelancing
An interim compliance officer is engaged through staff leasing or freelancing. Under staff leasing, the client has the right to give professional instructions and the specialist is integrated into its organisation; this suits leadership roles, formal functions and teams. Under freelancing, the specialist works independently within the agreed mandate, for example on a directives project or a risk analysis.
Legally, the two countries differ mainly in staff leasing:
- Switzerland – Personalverleih: anyone hiring out staff on a commercial basis needs a cantonal licence; hiring out staff from abroad into Switzerland is not permitted (Art. 12 of the Recruitment Act, AVG). The hiring agreement must be in writing (Art. 22 AVG). The AVG sets no statutory maximum assignment length.
- Germany – Arbeitnehmerüberlassung (German temporary agency work): the agency needs a licence from the Federal Employment Agency (section 1(1) of the Temporary Agency Work Act, AÜG). A worker may be assigned to the same client for at most 18 consecutive months (section 1(1b) AÜG).
- Freelancing: whether someone is genuinely self-employed is assessed case by case by the compensation office in Switzerland and, on application, by the German Pension Insurance in a status determination procedure in Germany (section 7a of Social Code Book IV).
Alpinum Solutions provides compliance specialists through staff leasing and freelancing, from junior analyst to interim head of compliance, part-time or full-time. In Switzerland, Alpinum Solutions AG hires out staff under a cantonal licence and a SECO licence for staff leasing abroad; in Germany, Alpinum Solutions GmbH holds a licence from the Hesse Regional Directorate of the Federal Employment Agency. The framework is explained in our guide to staff leasing of lawyers in Switzerland and Germany.
Typical assignments and duration
How long an assignment lasts depends on the trigger, from a few weeks to several months or longer. Typical triggers are:
- Vacancy: cover until the successor starts, including handover. A move into the team (temp-to-perm) is possible; the terms are agreed in advance.
- Parental or maternity leave: cover for the absence plus onboarding and handback. Planning is covered in our guide to planning parental leave in the legal department.
- Regulatory projects: for example the Swiss AML revision with its transparency register, in force since 1 October 2026, or preparing for the EU Anti-Money Laundering Regulation (AMLR), which applies from 10 July 2027.
- Remediation and backlogs: KYC reviews, transaction monitoring, measures following audit findings.
Example from practice
In 2025 a taskforce of 8 FTE, compliance officers including a team lead, worked full-time under staff leasing for a financial institution in Switzerland on KYC remediation, file reviews and alert handling. The team lead reported to internal compliance; the team started around two weeks after the order was placed, and the project was completed after 10 months. How to plan such a team is shown in our guide to planning KYC remediation.
Limits and risks
- Responsibility for compliance stays with senior management and the board. An interim compliance officer advises, monitors and reports, but does not replace decisions of the governing bodies.
- Authority, reporting lines and deputising should be agreed in writing before the start, especially for leadership roles.
- For formal functions such as the MLRO or the Swiss AML unit, regulatory requirements may rule out an external mandate or require staff leasing. Independence and responsibilities required by law are preserved.
- Alpinum is not a law firm and does not provide legal advice. Individual supervisory questions are for the institution to resolve with its audit firm and advisers.
Frequently asked questions about interim compliance officers
Can the anti-money laundering function be filled externally?
Under conditions. In Switzerland, a financial intermediary may designate external persons as its AML unit if an internal unit is not possible or disproportionate given its size or organisation (Art. 25(4) GwV-FINMA). In Germany, the MLRO function can be outsourced after prior notification (section 6(7) GwG). In both countries responsibility stays with the institution. Details in our guide to interim MLROs and AML project teams.
How long does a typical assignment last?
That depends on the trigger. A vacancy is covered until the successor starts; absence cover lasts for the absence plus onboarding. Projects follow milestones; the anonymised KYC taskforce of 8 FTE finished after 10 months. In Germany, temporary agency work is limited to 18 months with the same client; in Switzerland, staff leasing has no statutory maximum.
What does an interim compliance officer cost?
At Alpinum, day rates in Switzerland are CHF 800–1,200 for experienced specialists with three to six years' experience and CHF 1,200–1,800+ for seniors with seven years or more. In Germany they are EUR 720–960 (experienced) and EUR 960–1,440+ (senior) under staff leasing, and EUR 960–1,360 and EUR 1,360–2,000+ under freelancing. All figures exclude VAT, as of 18 October 2026. The calculation is explained in our guide to interim legal and compliance costs.
Can an interim compliance officer take on overall responsibility?
No. Overall responsibility for compliance stays with senior management and the board. An interim compliance officer can take on a leadership role or formal function with clearly agreed authority, set priorities and report. In Germany, the supervisory board must be informed in advance when the compliance officer changes (MaRisk AT 4.4.2), and the supervisor when the MLRO changes.
Staff leasing or freelancing for an interim compliance officer?
Staff leasing fits when the specialist is integrated into the team, systems and reporting lines and the company directs the work, for example for a vacancy or interim leadership. Freelancing fits clearly defined tasks delivered independently, such as a gap analysis. For formal functions, regulatory requirements may dictate the model. Both models work part-time and full-time.
Next step
Tell us about your organisation, the role and the time frame. Selected profiles are usually available within 48 hours; the start date is agreed jointly between the company and Alpinum.
- Interim compliance for companies and financial institutions
- Interim compliance: vacancy, project or backlog?
- Interim MLRO or AML project team
- Discuss your requirement
Last updated: 31 October 2026.
