SMF Capital

Welcome to SMF Capital, the specialist recruitment business for Senior Management Functions and senior regulatory appointments across UK financial services.

In this episode, we are looking at career opportunities for compliance officers, Heads of Compliance, Money Laundering Reporting Officers and financial crime professionals. We will explore the different types of roles available, what firms are looking for, how experienced compliance professionals can move into their first Senior Management Function appointment, and why permanent, interim and fractional opportunities are becoming increasingly important.

Whether you are an established SMF16 or SMF17 holder, a deputy looking for your first senior appointment, or an experienced compliance professional considering your next move, there are opportunities across a wide range of regulated sectors.

SMF Capital has dedicated jobs pages for both disciplines:

Compliance Officer Jobs: https://www.smfcapital.co.uk/compliance-officer-jobs/

MLRO and Financial Crime Jobs: https://www.smfcapital.co.uk/mlro-jobs/

These pages bring together current vacancies and provide a route for candidates to register confidentially for future opportunities.

1. Compliance Officer Jobs and the SMF16 Function

The Compliance Officer role is central to the operation of an FCA-regulated business. At firms subject to the Senior Managers and Certification Regime, the individual responsible for compliance oversight will generally hold the SMF16 function.

This is a significant appointment. The SMF16 holder is not simply responsible for checking policies or maintaining a compliance calendar. They must oversee the firm's compliance framework, provide effective challenge and ensure that important regulatory issues are brought to the attention of senior management and the board.

The precise responsibilities depend on the firm's permissions, activities, size and risk profile.

At a smaller financial services business, the Compliance Officer may be closely involved in day-to-day monitoring, financial promotions, complaints, regulatory returns and advice to the management team.

At a larger organisation, the role may involve leading a substantial compliance department, managing specialist teams, overseeing regulatory change and reporting to board committees.

SMF Capital recruits across both ends of the market, from hands-on compliance appointments at smaller directly authorised firms to senior Head of Compliance and Chief Compliance Officer positions.

2. What Does a Firm Look for in an SMF16 Candidate?

A strong compliance professional needs more than technical knowledge of FCA rules.

Firms want someone who can understand how the business actually operates, identify weaknesses and provide practical solutions without compromising regulatory standards.

Experience of running a risk-based compliance monitoring programme is particularly valuable. Employers will want to understand how you identified risks, carried out testing, reported findings and ensured that remedial actions were completed.

Board reporting is another important area. An effective SMF16 must be able to explain regulatory risks clearly, distinguish significant issues from routine matters and ensure that directors understand where action is required.

Consumer Duty has also become an important part of the compliance landscape. Firms increasingly need people who understand outcome testing, fair value assessments, customer communications, product governance and the evidence required to demonstrate that customers are receiving good outcomes.

Other areas of experience may include financial promotions, complaints handling, conduct risk, CASS, regulatory reporting, compliance policies and oversight of appointed representatives.

Sector experience matters too. A compliance officer from a wealth management business may have transferable skills, but an insurance broker, consumer credit lender or payments institution will often prefer someone who understands its particular products, permissions and regulatory risks.

3. Your First SMF16 Appointment

Moving into your first SMF16 position can be a significant career milestone.

Many candidates already perform much of the work associated with the function without formally holding the appointment. They may be a Compliance Manager, Deputy Head of Compliance or Senior Compliance Adviser who owns the monitoring programme, advises senior management and reports on regulatory matters.

The question is whether they have demonstrated the judgement, experience and independence needed to take personal responsibility for compliance oversight.

Firms will look at the candidate's previous responsibilities, regulatory history, ability to challenge senior colleagues and understanding of the business.

The FCA approval process is an important part of the appointment. Candidates should be prepared to demonstrate that they meet the fit and proper requirements and understand the responsibilities they are accepting.

SMF Capital works with firms and candidates to assess whether the opportunity is appropriate, rather than simply matching a job title to a CV.

4. Fractional, Interim and Part-Time Compliance Roles

Not every business needs a full-time Compliance Officer.

Smaller FCA-regulated firms may require an experienced SMF16 for one, two or three days a month. Others need interim support while a permanent appointment is being made, during a regulatory remediation programme or following the unexpected departure of an existing senior manager.

This has created a substantial market for fractional and interim

Welcome to another episode from SMF Capital.

Today we're looking at something particularly practical for FCA-regulated firms: free compliance templates.

It's one thing to understand what the FCA expects. It's another thing to actually create the documents and governance structures needed to demonstrate that your firm is meeting those expectations.

SMF Capital has created a collection of free templates designed to give smaller regulated businesses a practical starting point.

You can access the full library here:

SMF Capital Free Guides & Templates

Statement of Responsibilities Template

Let's start with one of the most important documents under the Senior Managers and Certification Regime: the Statement of Responsibilities.

Every Senior Manager needs to understand exactly what they are responsible for.

The Statement of Responsibilities should clearly describe the areas for which the individual has responsibility and should align with the firm's overall governance structure.

SMF Capital provides a free Statement of Responsibilities Template to help firms structure this document.

Statement of Responsibilities Template

It can be particularly useful when appointing a new Senior Manager, restructuring responsibilities or preparing for FCA authorisation.

Responsibilities Map Template

The Statement of Responsibilities deals with an individual.

The Responsibilities Map looks at the firm as a whole.

It helps demonstrate how responsibilities are allocated across the senior management team.

This becomes particularly important as a regulated business grows and multiple Senior Managers become involved.

The free SMF Capital template provides a starting point for creating a clear responsibilities map.

Responsibilities Map Template

Fit and Proper Assessment Template

The FCA expects firms to assess whether relevant individuals are fit and proper to perform their roles.

That means considering areas such as honesty, integrity, reputation, competence, capability and financial soundness where relevant.

A structured assessment process helps the firm demonstrate that it has considered these issues rather than simply assuming that an experienced individual is suitable.

SMF Capital provides a free Fit and Proper Assessment Template that firms can use as a starting point.

Fit and Proper Assessment Template

Board Skills Matrix

Governance isn't only about individual Senior Managers.

The board as a whole needs to have an appropriate combination of skills and experience.

A Board Skills Matrix can help identify strengths, gaps and areas where additional expertise may be required.

SMF Capital's free template provides a practical way to structure this assessment.

Board Skills Matrix Template

This can be particularly useful when reviewing the board following growth, a change in ownership or the appointment of new directors.

Compliance Monitoring Plan

Another important practical resource is the Compliance Monitoring Plan Template.

A compliance monitoring programme should test whether the firm's policies and controls are actually operating as intended.

It can cover areas such as regulatory permissions, financial promotions, complaints, Consumer Duty, financial crime, client money and other risks relevant to the firm's business.

The template gives smaller firms a starting point for structuring their monitoring programme.

Compliance Monitoring Plan Template

Why templates can be useful

For smaller regulated firms, creating these documents from scratch can take considerable time.

A template doesn't remove the need to tailor the document to the firm's circumstances.

In fact, that's one of the most important points.

A Responsibilities Map should reflect the firm's actual management structure.

A Statement of Responsibilities should describe what the individual really does.

A Fit and Proper Assessment needs to consider the actual role and individual.

And a compliance monitoring plan needs to reflect the firm's specific regulatory risks.

The templates provide a framework. The firm needs to make that framework its own.

Combining the templates

These resources are particularly useful when used together.

For example, a firm preparing for FCA authorisation might establish its senior management structure, complete a Responsibilities Map, prepare individual Statements of Responsibilities, assess the fitness and propriety of the proposed Senior Managers and then establish a compliance monitoring programme.

The result is a much more coherent governance framework than treating each document as an isolated exercise.

When specialist expertise is needed

Templates are useful, but sometimes a firm needs more than a document.

A growing regulated business may need an experienced SMF16 Compliance Officer, MLRO, Risk Director or other Senior Manager.

A firm becoming directly authorised may need help identifying the right people before submitting its application.

An existing business may need an interim compliance officer while recruiting permanently.

That's where SMF Capital's specialist recruitment service can help.

The purpose of the free resources isn't to replace specialist expertise where it is required.

It's to give regulated firms useful information and practical starting points.

Free means free

All of these resources are available without charge.

There is no need to purchase a consultancy report simply to access the templates.

SMF Capital has created them specifically to help regulated firms understand and organise their governance and compliance responsibilities.

To see the complete collection, visit:

SMF Capital Free Guides & Templates

Final thoughts

Good regulatory governance starts with clarity.

Who is responsible?

What are they responsible for?

Are they fit and proper?

Does the board have the right skills?

And is the firm's compliance programme actually testing whether its controls work?

The free SMF Capital templates provide practical starting points for answering those questions.

Visit the SMF Capital Free Guides & Templates library and access the resources for your own firm.

And if your business needs experienced senior compliance or regulatory professionals, SMF Capital can also help with fractional, interim and permanent appointments.

Today we're talking about something slightly different from our usual discussions about senior compliance recruitment.

SMF Capital has created a growing library of free guides and practical resources for FCA-regulated firms, particularly smaller businesses that need to understand their regulatory responsibilities without immediately bringing in a large consultancy team.

The resources are available completely free from the SMF Capital website.

You can access the full collection here:

SMF Capital Free Guides & Templates

Why create free guides?

Running an FCA-regulated business involves a huge amount of responsibility.

Senior managers need to understand their individual responsibilities, firms need appropriate governance structures, and businesses need to demonstrate that they have suitable people and controls in place.

For a smaller firm, knowing where to start isn't always straightforward.

That's why SMF Capital has created practical guides covering subjects such as Senior Management Functions, Statements of Responsibilities, MLRO appointments, direct authorisation and compliance monitoring.

The aim is to make these subjects easier to understand.

Who can be your MLRO?

One of the free guides looks at a particularly important question for smaller regulated firms:

Who can actually be your MLRO or Compliance Officer?

Smaller firms don't always need separate full-time specialists for every regulatory function.

Depending on the firm's activities, size and regulatory status, one person may be able to perform more than one role.

But there are important considerations around competence, capacity, conflicts and FCA approval.

The guide explains the issues firms should consider before making an appointment.

Who Can Be Your MLRO?

Can one person hold two SMFs?

Another free guide examines whether one person can hold more than one Senior Management Function.

This is particularly relevant to smaller firms.

Combining roles can sometimes be practical, but it isn't simply a question of putting two job titles against the same individual.

The firm needs to consider whether the individual has the competence, time and authority to perform both functions effectively.

The guide looks at the practical considerations involved.

Can One Person Hold More Than One SMF?

Going directly authorised

Another major area covered by the free resources is becoming directly authorised.

For businesses currently operating as appointed representatives, moving to direct FCA authorisation can be a major step.

The firm takes responsibility for its own compliance framework, senior management, governance and regulatory reporting.

That means understanding which Senior Managers will be required and what responsibilities they will hold.

SMF Capital's guide explains the senior management appointments that firms need to consider.

Going Directly Authorised

Becoming a directly authorised insurance broker

There is also a dedicated guide for insurance brokers.

Becoming a directly authorised insurance broker involves considering the business model, financial resources, compliance arrangements, client money, Senior Management Functions and the FCA application itself.

For an experienced insurance broker considering leaving a network, this can be particularly useful.

Becoming a Directly Authorised Insurance Broker

Becoming an Enhanced firm

For firms approaching or already operating under the Enhanced regime, the senior management requirements become even more significant.

SMF Capital has produced a guide explaining the additional SMF appointments that can arise when a firm becomes an Enhanced firm.

Becoming an Enhanced Firm

Compliance monitoring

A good compliance framework needs more than policies.

The firm needs to monitor whether those policies are actually working.

SMF Capital therefore also provides a Compliance Monitoring Plan Template, giving firms a practical starting point for structuring their monitoring programme.

Compliance Monitoring Plan Template

A library rather than a single guide

The real value of the SMF Capital resource centre is that these guides can be used together.

A firm considering direct authorisation might start with the guide on Senior Management Functions, then look at the insurance broker guide if applicable, and use the compliance monitoring template when building its regulatory framework.

A smaller established firm might be considering whether one person can hold multiple SMFs, who should act as MLRO, and how its compliance monitoring programme should operate.

The resources are designed to help answer those questions.

And they're free

There's no charge for accessing these guides and templates.

You don't need to purchase a report or sign up for a consultancy package simply to read the material.

The objective is to provide useful information that helps FCA-regulated businesses understand the issues they need to address.

Of course, there will be circumstances where a firm needs specialist professional advice or wants to recruit an experienced compliance professional.

That's where SMF Capital's specialist recruitment service comes in.

Final thoughts

Whether you're setting up a regulated firm, becoming directly authorised, moving into the Enhanced regime, reviewing your Senior Management Functions or simply trying to strengthen your compliance framework, there are practical resources available from SMF Capital.

Visit the Free Guides & Templates section to see the full collection.

SMF Capital Free Guides & Templates

They're designed specifically to help regulated firms understand their responsibilities and make better-informed decisions about their governance and senior compliance requirements.

Welcome to another episode from SMF Capital. Today, we're looking at how insurance brokers can become directly authorised by the Financial Conduct Authority, the people they need in place, and how to prepare for the application process.

Whether you're establishing a new brokerage or leaving a network after operating as an appointed representative, direct authorisation offers greater independence. But it also means taking responsibility for compliance, governance, financial resources and regulatory reporting.

Read our full guide here:

Becoming a Directly Authorised Insurance Broker

Two routes to authorisation

The first route is setting up a new brokerage. The founders need to establish the business model, regulatory policies, financial arrangements and senior management structure.

The second is leaving an existing network. An appointed representative must replace the support previously provided by its principal, including compliance oversight, file checking, training, complaints handling, financial promotions approval and regulatory reporting.

In both cases, the FCA needs to be satisfied that the firm meets the relevant threshold conditions, including having suitable people, adequate resources and effective systems.

Which senior managers are required?

For most directly authorised insurance brokers, the Senior Managers and Certification Regime is central to the application.

A typical structure includes an SMF1 Chief Executive or SMF3 Executive Director and an SMF16 Compliance Oversight function.

The founder may hold the executive role, while a specialist compliance officer oversees the regulatory framework. At a smaller brokerage, the compliance officer can be fractional, provided there is sufficient time and authority to perform the role effectively.

An SMF17 Money Laundering Reporting Officer may also be required, depending on the firm's activities. General insurance alone is generally outside the Money Laundering Regulations, but firms arranging life or investment-related insurance need to assess their obligations.

Each relevant Senior Manager needs the appropriate application documentation, including a Statement of Responsibilities and evidence of fitness and propriety.

Financial requirements

Insurance brokers must meet the applicable prudential requirements under the FCA's MIPRU rules.

The fixed minimum capital requirement depends partly on whether the firm holds client money:

• No client money: £5,000 fixed minimum.
• Statutory trust: £10,000 fixed minimum.
• Non-statutory trust: £50,000 fixed minimum.

Income-based calculations also apply, and the firm generally needs to meet whichever requirement is higher.

Capital isn't the only consideration. The FCA will also expect realistic financial projections, adequate working capital, suitable professional indemnity insurance and a credible plan for remaining viable.

The current FCA Handbook requirements should always be checked when preparing the application.

Client money: decide early

Some brokers arrange for premiums to be paid directly to insurers or use appropriate risk transfer agreements. Others receive and hold client money themselves.

That decision affects capital requirements, accounting systems, controls and audit obligations under CASS 5.

Where client money is held, the firm needs appropriate accounts, calculations, reconciliations and oversight.

The choice also influences the experience required from the compliance officer and finance team.

For more detail, see SMF Capital's CASS 5 guide.

Preparing the application

Applications are made through FCA Connect. A strong application should explain how the firm will operate and demonstrate that its regulatory arrangements are practical.

Key elements include:

• A regulatory business plan covering customers, products, distribution and risks.
• Senior Manager applications and Statements of Responsibilities.
• Compliance and financial crime policies.
• A compliance monitoring plan.
• Financial projections and capital calculations.
• Evidence of professional indemnity insurance.
• Arrangements for overseeing appointed representatives, where applicable.
• Training and competence arrangements for relevant staff.

Policies should reflect the actual business rather than relying on generic templates. A commercial insurance broker, for example, needs controls suited to its customers, products and distribution model.

Under section 55V of the Financial Services and Markets Act, the FCA has six months to determine a complete application and twelve months for an incomplete one. These are statutory decision periods, not guaranteed approval dates.

Build the team in the right order

First, appoint the compliance officer. An experienced SMF16 can help shape the business plan, policies and monitoring programme before the application is finalised.

Second, establish whether an MLRO is required. This depends on the firm's activities and the Money Laundering Regulations.

Third, arrange finance support. Someone needs to manage capital calculations, financial projections and future regulatory returns.

Fourth, confirm governance. Decide which Senior Managers will hold each function and prepare appropriate Statements of Responsibilities.

Finally, submit a complete application. The directors and proposed Senior Managers should understand the business and be ready to explain how its controls will operate.

Allow several months to prepare before submission. Recruiting an experienced compliance officer early can reduce the risk of gaps emerging late in the process.

Leaving a network

An appointed representative leaving a network needs to plan carefully.

The principal may previously have provided compliance monitoring, file checking, training, complaints handling, financial promotions approval and reporting. The new directly authorised firm must establish its own appropriate arrangements.

Plan the exit early, agree how existing business and complaints will be handled, and identify the compliance officer before giving notice where possible.

Many former ARs use a fractional SMF16 during their first year, reviewing the arrangement as the business grows.

Common mistakes

Problems can arise when firms leave the compliance appointment until late, underestimate capital requirements or submit generic Statements of Responsibilities.

Another mistake is assuming a consultancy contract automatically provides an approved SMF16. The firm needs to identify the individual holding the relevant function and establish clear accountability.

Directors must also understand their own responsibilities rather than relying entirely on an external adviser.

A practical example

Imagine three experienced commercial brokers leaving a large network to establish their own brokerage.

Their initial application names the managing director as compliance officer, despite that director also having a demanding sales role.

A better solution may be a fractional SMF16 with direct insurance broker authorisation experience.

The compliance officer can tailor the Consumer Duty and product governance policies, establish the monitoring programme and clarify whether the business falls within the Money Laundering Regulations.

The firm can then submit an application supported by a more credible governance structure.

How SMF Capital helps

SMF Capital helps insurance brokers identify the senior professionals required for authorisation and ongoing regulatory compliance.

Depending on the firm's needs, this may include fractional, interim and permanent compliance officers, MLROs and other senior regulatory professionals.

We consider the firm's business model, permissions, size and growth plans before identifying suitable candidates.

For a new brokerage, that may mean a fractional SMF16 and part-time finance support. A larger firm may need a broader senior management team.

Every broker recruitment search is overseen by Adrian Lawrence FCA, founder of SMF Capital.

Final thoughts

Direct authorisation creates independence, but it also brings responsibility.

A successful application needs suitable people, adequate financial resources, effective governance and compliance arrangements that work in practice.

The best approach is to plan the management structure early, involve the compliance officer before the application is complete and ensure that every policy reflects the actual business.

Whether you're launching a new brokerage or leaving a network, the right senior appointments can provide a stronger foundation for authorisation and future growth.

For further guidance and recruitment support, visit SMF Capital's guide to becoming a directly authorised insurance broker.

Welcome to another episode from SMF Capital, exploring the people and expertise required by FCA-regulated businesses.

Today, we're looking at CASS 5, the FCA's client money rules for insurance brokers and intermediaries. We'll explain the main requirements, common problems and why having the right finance and compliance professionals is essential.

Read the full guide at SMF Capital – CASS 5 Client Money.

What is CASS 5?

CASS 5 applies to insurance intermediaries that receive or hold money for clients in connection with insurance distribution.

Examples include premiums collected before being paid to insurers, and claims or refunds received before being passed to customers.

The objective is to protect client money if an insurance broker fails. Firms need appropriate arrangements, accurate records and effective controls to ensure money is handled correctly.

Understanding risk transfer

Risk transfer is one of the most important concepts in insurance broker accounting.

Where an appropriate risk transfer agreement exists, money received by the broker as the insurer's agent is treated as received by the insurer. That money is not client money under CASS 5.

However, many brokers handle a mixture of risk-transfer money and client money. They must understand which category each payment belongs to and ensure their records reflect the distinction.

Getting this wrong can affect calculations, reconciliations and audit results.

Statutory and non-statutory trusts

Insurance brokers need to understand the trust arrangements governing their client money.

A statutory trust is the default arrangement under CASS 5. A non-statutory trust can offer greater flexibility, including allowing credit to be advanced in certain circumstances, such as paying an insurer before a customer has paid.

That flexibility comes with additional conditions, higher minimum capital requirements and stronger control expectations.

The choice of trust should therefore be made with appropriate professional advice, taking account of the firm's business model and cash-flow requirements.

Client bank accounts and acknowledgement letters

Client money must be held in designated accounts, separate from the firm's own money, with the appropriate bank acknowledgement that the funds are held on trust.

Where money passes to other parties, equivalent protections and acknowledgements may also be required.

Missing or outdated acknowledgement letters are a common audit weakness. Brokers should ensure the arrangements remain accurate as banking relationships and business processes change.

The client money calculation

Firms must regularly check that their client money resources cover their client money requirements.

The calculation must be performed at least every 25 business days. Depending on the firm's arrangements, it can use the client balance method or the accruals method.

Any shortfall must be corrected on the same day, using the firm's own money where necessary. Excess client money must also be addressed appropriately.

Records should be reconciled against bank statements, differences investigated promptly and supporting evidence retained. Money handled by appointed representatives must also be included where required.

If a firm cannot perform the calculation or correct a shortfall, it must notify the FCA immediately.

These are ongoing operational responsibilities, not simply year-end accounting tasks.

Why insurance accounting expertise matters

CASS 5 requires people who understand how insurance money moves through the business.

Relevant experience may include insurance premiums, insurer and customer ledgers, unearned commission, risk transfer arrangements, client money calculations and reconciliations.

A general bookkeeper may have strong accounting skills but lack the specialist knowledge needed to manage these requirements effectively.

That is why insurance-specific client money experience is important when recruiting finance professionals.

Who is accountable?

Under the Senior Managers and Certification Regime, responsibility for CASS compliance is allocated to a Senior Manager through a Prescribed Responsibility.

At a smaller broker, this might be the managing director or compliance officer. In a larger organisation, it could be the Finance Director.

The responsible Senior Manager needs appropriate management information and evidence that the controls are operating effectively.

Although tasks can be delegated, accountability for the overall arrangements cannot simply be handed to a junior employee.

The three key roles

Effective client money oversight can involve three distinct responsibilities.

First, the finance professional prepares the calculations, maintains records and performs reconciliations.

Second, the compliance officer oversees the regulatory framework, challenges weaknesses and checks that controls are effective.

Third, the Senior Manager holding the CASS Prescribed Responsibility maintains appropriate oversight and receives sufficient information to understand the firm's position.

In smaller businesses, some duties may be combined, but responsibilities and appropriate checks still need to be clear.

Experience also needs to match the regulatory regime. Knowledge of CASS 7 at an investment firm does not automatically provide the specialist understanding of insurance risk transfer and trust arrangements required under CASS 5.

CASS audits and common weaknesses

Insurance brokers holding client money must meet the relevant reporting requirements and obtain an annual client assets report from their auditor, which is sent to the FCA.

Auditors examine calculations, reconciliations, bank arrangements, acknowledgement letters and internal controls.

Common weaknesses include late calculations, uncorrected shortfalls, missing bank acknowledgements, poor reconciliations and inadequate review.

Using client money to fund the firm's own cash flow can be particularly serious.

A qualified audit report or significant control failures may attract further regulatory scrutiny. A sound framework must therefore operate throughout the year, not just before the audit.

Appointed representatives

Where appointed representatives handle premiums, the principal needs to understand how that money is managed and ensure the relevant amounts are included in its client money calculations.

Weak oversight of ARs can create additional risks and potential shortfalls.

As a broker expands its AR network, it may need stronger monitoring processes and clearer reporting to maintain effective control.

Setting up CASS 5 at a new broker

New brokers should establish their client money arrangements before they begin receiving premiums.

This involves mapping money flows, agreeing risk transfer arrangements, choosing the appropriate trust structure, opening designated accounts and establishing the calculation method.

The firm should also appoint an auditor and decide who prepares, reviews and oversees the calculations.

Planning these arrangements early helps demonstrate how client money will be protected and supports a more effective authorisation process.

Finding the right people

Consider a growing commercial broker whose auditor identifies repeated client money shortfalls that were not corrected on the same day. The calculations were being prepared by a bookkeeper without specialist review.

The solution may involve recruiting a finance manager with insurance accounting experience, introducing a formal review process and appointing a fractional compliance officer with CASS 5 expertise.

The Senior Manager responsible for CASS can then receive better information and exercise more effective oversight.

The goal is not merely to pass the next audit. It is to build controls that work consistently.

How SMF Capital can help

As insurance brokers grow, finding people with the right combination of accounting, compliance and insurance experience can be challenging.

SMF Capital supports recruitment for insurance brokers and other FCA-regulated businesses, including fractional, interim and permanent compliance appointments. We can also help firms identify finance professionals with relevant client money experience.

The key is matching the candidate's experience to the firm's actual requirements rather than assuming that knowledge of another regulatory regime is sufficient.

Every SMF Capital broker search is overseen by Adrian Lawrence FCA.

Final thoughts

CASS 5 is about protecting client money through accurate calculations, appropriate trust arrangements, effective reconciliations and clear accountability.

The finance team needs to understand the numbers. Compliance needs to challenge the controls. And the Senior Manager holding the relevant responsibility needs sufficient information to maintain effective oversight.

For brokers preparing for authorisation, growing their business or addressing client money weaknesses, getting the right people in place can make a substantial difference.

For further guidance and recruitment support, visit SMF Capital's CASS 5 guide.

Welcome to another episode from SMF Capital, focusing on senior compliance appointments within FCA-regulated businesses.

Today we're looking at an increasingly common requirement: finding a Compliance Officer for an insurance broker or MGA, particularly where the business needs experienced regulatory oversight without necessarily employing a full-time Head of Compliance.

You can find the full SMF Capital guide here:

Compliance Officer for Insurance Brokers and MGAs

Why insurance experience matters

Insurance broking has its own regulatory requirements and risks.

A compliance officer working with an insurance broker may need experience across ICOBS, Consumer Duty, product governance, financial promotions, complaints, regulatory reporting, client money and appointed representative oversight.

That means general FCA compliance experience isn't always enough.

A candidate who has worked predominantly in banking, investments or another regulated sector may understand FCA regulation very well, but may not have the practical experience required to oversee an insurance broker.

For example, an insurance broker may need someone who understands demands and needs, suitability where advice is provided, customer communications, product governance and the practical application of Consumer Duty.

Client money can also be an important consideration where the broker operates under CASS 5 arrangements.

The SMF16 requirement

For many directly authorised insurance brokers, compliance oversight is an important senior management responsibility.

Where SMF16 Compliance Oversight applies, the function must be held by an individual approved by the FCA.

That doesn't necessarily mean employing a full-time compliance officer.

A smaller broker may only require an experienced compliance professional for a few days each month, while a larger broker or MGA may need substantially more resource.

The key is matching the compliance resource to the firm's size, complexity, permissions and risks.

Fractional compliance officers

A fractional compliance officer can be particularly useful for smaller insurance businesses.

Instead of employing a permanent Head of Compliance, the firm can appoint an experienced professional for perhaps two, three or four days a month.

The arrangement can then increase as the business grows.

This can work particularly well for:

• New insurance brokers applying for FCA authorisation
• Small directly authorised brokers
• Specialist commercial or personal lines brokers
• Growing insurance intermediaries
• Brokers with appointed representatives
• Businesses replacing an existing compliance officer
• MGAs requiring specialist regulatory expertise

The objective shouldn't simply be to find the cheapest solution.

The objective is to obtain sufficient senior compliance expertise to properly oversee the business.

Insurance brokers and Consumer Duty

Consumer Duty has increased the importance of effective compliance oversight.

An insurance broker needs to be able to demonstrate that customers receive good outcomes and that products and services are appropriate for the markets being served.

A compliance officer may therefore be involved in reviewing:

• Customer communications
• Product governance
• Fair value assessments
• Complaints
• Customer outcomes
• Monitoring programmes
• Management information
• Financial promotions

The compliance officer should be able to translate regulatory requirements into practical processes rather than simply producing policies that sit in a compliance folder.

Appointed representatives

Appointed representatives can add another layer of complexity.

Where a broker acts as principal, the compliance function may need to oversee AR relationships, monitoring, financial promotions, training, governance and ongoing regulatory risks.

That makes previous AR experience particularly valuable.

A compliance officer who has already dealt with principal and AR relationships can often identify problems much earlier than someone who has only worked within a simpler directly authorised business.

What about MGAs?

MGAs can have a different compliance profile from conventional insurance brokers.

Depending on their business model, they may have responsibilities involving delegated underwriting authority, product governance, claims arrangements, capacity providers and relationships with insurers or Lloyd's.

Consequently, an MGA may benefit from a compliance officer with direct experience of delegated authority and the insurance market.

This is one reason specialist recruitment can be useful.

Rather than searching for a generic compliance professional, the recruitment process can focus on people who have actually operated within the relevant part of the insurance sector.

Does the same person hold SMF16 and SMF17?

This depends on the firm's activities.

A general insurance broker may not have the same money-laundering obligations as a business involved in life or investment-related insurance.

However, where an MLRO is required, smaller firms can sometimes use the same individual for SMF16 Compliance Oversight and SMF17 Money Laundering Reporting Officer.

The important point is to assess the firm's actual activities, permissions and regulatory requirements rather than assuming that every insurance broker needs exactly the same structure.

How many days a month?

There is no standard number.

A small broker may need two or three days a month.

A growing firm with more customers, client money or appointed representatives may require substantially more time.

An MGA with complex delegated authority arrangements may need a regular weekly commitment.

Eventually, a larger organisation may need a permanent Head of Compliance supported by a compliance team.

A good compliance assessment should therefore consider the firm's current position as well as its growth plans.

What should you look for?

When recruiting a compliance officer for an insurance broker, some of the most useful areas to investigate include:

• Previous SMF16 experience
• Direct insurance broking experience
• ICOBS knowledge
• Consumer Duty
• Product governance
• CASS 5 where relevant
• Appointed representative oversight
• Financial promotions
• Complaints
• FCA authorisation experience
• Compliance monitoring
• Understanding of the firm's particular insurance products

Professional insurance qualifications can also be useful, but practical regulatory experience is equally important.

The candidate should also have sufficient capacity.

A fractional compliance officer supporting too many businesses may not have enough time to properly understand another firm's risks.

What happens if the compliance officer leaves?

Replacing an SMF16 can become urgent if a compliance officer resigns.

The business still needs appropriate compliance oversight while it searches for a permanent replacement.

An interim or fractional compliance officer can provide continuity during the recruitment process.

The 12-week rule can also be relevant when arranging temporary cover, subject to the circumstances and applicable FCA requirements.

This can be particularly valuable for smaller brokers that don't have a large internal compliance team capable of absorbing the responsibilities.

When should you move to a permanent hire?

A fractional model isn't necessarily a permanent solution.

As the broker grows, there may come a point where compliance volumes justify a full-time appointment.

Indicators can include:

• Rapid growth in customer numbers
• Increasing complaints
• More complex permissions
• Several appointed representatives
• Significant client money responsibilities
• New products or markets
• Increased FCA scrutiny
• A larger compliance monitoring programme

At that point, the business may recruit a permanent Head of Compliance while continuing to use specialist external support where appropriate.

How SMF Capital helps

SMF Capital starts by understanding the business rather than simply taking a job title.

We look at the firm's activities, permissions, customer base, client money arrangements, appointed representatives, regulatory risks and future plans.

That helps determine what level of compliance resource is actually required.

We can then identify candidates with relevant insurance broker or MGA experience, including fractional, interim, part-time and permanent compliance officers.

pliance professional.

Welcome to the SMF Capital podcast.

Today we're looking at a question increasingly being asked by smaller and growing FCA-regulated firms:

Do you need a full-time Compliance Officer, or could an outsourced or fractional Compliance Officer provide the right solution?

SMF Capital has produced a detailed guide to outsourced Compliance Officers:

Outsourced Compliance Officer – SMF Capital

For many smaller regulated firms, a full-time senior compliance appointment may not be necessary. But that does not mean the firm's compliance responsibilities disappear.

The challenge is finding the right balance between cost, expertise, independence and regulatory accountability.

What Does "Outsourced Compliance Officer" Actually Mean?

This is where an important distinction needs to be made.

A firm can outsource compliance work such as monitoring, file reviews, policy development and regulatory advice.

But that is not necessarily the same thing as having an outsourced Compliance Officer.

Under the Senior Managers and Certification Regime, the SMF16 Compliance Oversight function must be held by an appropriately approved individual.

A consultancy itself cannot simply become the accountable SMF16.

There needs to be a named individual who holds the responsibility.

That individual could work for a consultancy, or could be engaged directly on a fractional basis.

This distinction is extremely important for firms considering outsourced compliance.

Why Would a Firm Choose a Fractional Compliance Officer?

For a small FCA-regulated business, employing a senior Compliance Officer five days a week may not make commercial sense.

The firm may have a relatively small number of customers, straightforward operations and limited regulatory complexity.

But it still needs proper compliance oversight.

Someone needs to oversee the compliance monitoring programme, review breaches and complaints, keep policies current, consider regulatory developments and report to the board.

A fractional Compliance Officer can provide that senior expertise for a defined number of days each month.

The arrangement can therefore be proportionate to the size and risk profile of the business.

It can also give the firm access to someone with considerably more experience than it might otherwise be able to afford on a full-time basis.

Who Uses Outsourced Compliance Officers?

There are several situations where this model can work particularly well.

Small directly authorised firms may need an experienced SMF16 without requiring a full-time appointment.

A firm applying for FCA authorisation may need a named Compliance Officer as part of its regulatory structure.

A payments, e-money or crypto business in its early years may need specialist compliance leadership while it develops.

Investment managers and family offices with relatively small regulated operations may also benefit.

And an established firm that has suddenly lost its Compliance Officer may need interim or fractional cover while recruiting permanently.

In some smaller businesses, the same person may also hold the SMF17 MLRO function, provided they have the necessary experience, approval and capacity.

What Should You Look For?

Choosing an outsourced Compliance Officer should not simply be a matter of finding the cheapest available option.

The individual's previous experience matters.

Have they actually held SMF16 before?

Have they worked with firms operating under the same regulatory framework?

Do they understand the firm's particular sector?

An insurance broker, for example, needs different expertise from a payments business.

An investment manager has different compliance risks from a consumer credit lender.

Time commitment is also important.

A Compliance Officer may be working with several businesses.

The firm needs to establish how many days they will dedicate to its work, how quickly they can respond to urgent issues and what happens when they are unavailable.

The individual should also have appropriate access to the board and the information required to perform the function effectively.

Finally, there should be a clear agreement covering responsibilities, confidentiality, conflicts, access, time commitment and arrangements for cover.

What Should an Outsourced Compliance Officer Do?

A genuine outsourced Compliance Officer should be actively involved in the firm's compliance framework.

That can include overseeing the compliance monitoring programme and following up findings.

They may review complaints, breaches and incidents and determine whether matters require escalation.

They may approve financial promotions and review customer communications.

They should keep policies and procedures aligned with regulatory developments.

Consumer Duty information and customer outcomes may also need to be reviewed.

The Compliance Officer should report to the board and attend relevant meetings, while also ensuring that the firm can demonstrate effective compliance oversight.

The important point is that the arrangement should produce evidence that the function is actually operating.

Simply having a consultancy agreement on file is not enough.

Independence Is Important

One advantage of an external or fractional Compliance Officer can be independence.

In a small company, directors are often heavily involved in commercial activity.

It can be difficult for an internal employee who reports directly to those directors to challenge decisions effectively.

An experienced Compliance Officer should be prepared to provide constructive challenge.

That might mean questioning a financial promotion, identifying weaknesses in a monitoring programme or escalating a regulatory concern.

The objective is not to obstruct the business.

It is to ensure that commercial growth takes place within an appropriate regulatory framework.

Outsourced Compliance Support vs SMF16

This is probably the most important point for firms considering outsourcing.

A consultancy can provide valuable compliance support without providing the firm's actual SMF16.

For example, an external consultancy might carry out compliance monitoring while a director within the firm remains responsible for the compliance oversight function.

Alternatively, the firm can appoint a named fractional Compliance Officer who is approved as SMF16, with a consultancy providing additional support around that person.

Those are different arrangements.

Businesses need to understand exactly which model they are buying.

When Should You Bring Compliance In-House?

An outsourced Compliance Officer can work for many firms for a considerable period.

But the arrangement should be reviewed as the business grows.

Increasing customer numbers, higher complaint volumes, new products, additional regulatory permissions or greater regulatory complexity may eventually justify a full-time appointment.

A firm may then move to an internal Compliance Officer while continuing to use external specialists for particular reviews or projects.

The important thing is to ensure that the compliance structure evolves with the business.

Why Use a Specialist Recruitment Firm?

Finding an outsourced Compliance Officer is not simply about finding someone available for a few days a month.

The person needs the right regulatory experience, sector knowledge and approval history.

They need to have sufficient capacity to give the firm proper attention.

They also need to be comfortable operating at board level and challenging senior management when necessary.

This is where specialist recruitment can be particularly useful.

SMF Capital focuses specifically on Senior Management Function recruitment and understands the difference between general compliance support and an individual who can take on the SMF16 responsibility.

The search can be built around the firm's sector, permissions, risk profile, required time commitment and longer-term plans.

Final Thoughts

For many smaller FCA-regulated firms, the choice does not have to be between employing a full-time Compliance Officer and trying to manage compliance internally.

A properly structured fractional or outsourced Compliance Officer can provide experienced senior oversight without the cost of a full-time appointment.

But firms need to understand exactly what they are buying.

Outsourcing compliance tasks is not the same as appointing an approved individual to hold SMF16.

The right Compliance Officer needs the appropriate experience, authority, independence and time to perform the function properly.

If your firm is considering an outsourced Compliance Officer, fractional SMF16 or interim compliance arrangement, the SMF Capital guide provides a useful starting point.

Read the full Outsourced Compliance Officer guide

Thank you for listening to the SMF Capital podcast.

Today we're looking at four specialist recruitment businesses that cover some of the most important senior, regulatory, finance and tax appointments facing UK businesses:

SMF Capital, Regulatory Capital, Tax Capital and FD Capital Group.

The four websites are:

www.smfcapital.co.uk

www.regulatorycapital.co.uk

www.taxcapital.co.uk

www.fdcapitalgroup.co.uk

Together, they represent a specialist approach to recruitment: rather than trying to be everything to everyone, each business focuses on a particular area of expertise.

SMF Capital

Let's start with SMF Capital.

SMF Capital specialises in Senior Management Function recruitment for FCA-regulated firms.

That means recruiting people whose appointments can carry direct regulatory accountability.

The business covers roles including SMF1 Chief Executive, SMF2 Chief Finance Function, SMF4 Chief Risk Officer, SMF5 Head of Internal Audit, SMF16 Compliance Officer, SMF17 MLRO and SMF24 Chief Operating Officer, together with chairs, committee chairs and other senior functions.

What makes an SMF appointment different from conventional executive recruitment is that the regulator has a view on the appointment.

The candidate needs to meet the relevant fit and proper requirements and be capable of carrying the responsibilities attached to the function.

That means the recruitment process needs to consider regulatory suitability from the beginning rather than treating FCA approval as something that happens after the hiring decision.

SMF Capital also provides fractional and interim SMF cover.

That can be particularly valuable when a regulated firm suddenly loses a Compliance Officer or MLRO, needs temporary cover during an approval process, or is too small to require a full-time senior appointment.

The business also supports firms going through authorisation, governance reviews, board restructuring and multi-SMF team builds.

For FCA-regulated businesses, specialist knowledge can make a significant difference.

Regulatory Capital

The second specialist area is Regulatory Capital.

Capital is fundamental to regulated financial services.

A regulated business may need specialist knowledge of prudential requirements, capital calculations, liquidity, regulatory reporting, stress testing and the particular framework applicable to its business model.

The requirements facing an investment firm are not necessarily the same as those facing a bank, insurer, payments business or other regulated organisation.

That is why regulatory capital recruitment requires more than simply finding someone with a conventional finance background.

The right candidate needs to understand the interaction between finance, regulation and the firm's business model.

This can be particularly important when a business is growing, changing its regulatory permissions, preparing for authorisation or facing increasing prudential complexity.

The finance professional may need to communicate with the board, regulators and other control functions while ensuring that commercial decisions remain consistent with the firm's capital position.

Regulatory Capital is therefore focused on the specialist people who understand that environment.

Tax Capital

The third specialist business is Tax Capital.

Tax is another area where technical expertise matters enormously.

Modern businesses can face complex requirements involving corporation tax, international tax, VAT, indirect tax, transfer pricing, employment tax and other specialist areas.

At senior level, a tax professional is not simply responsible for compliance.

They may be involved in acquisitions, international expansion, group structuring, tax risk, strategic planning and discussions with the board.

The difference between someone with general tax exposure and someone who genuinely specialises in the relevant discipline can therefore be substantial.

Tax Capital focuses on connecting businesses with professionals who have the technical expertise required for their particular tax requirements.

That could mean a senior Tax Director, corporate tax specialist, VAT professional, international tax expert or another specialist tax appointment.

The principle is straightforward: the more complex the requirement, the more important genuine specialisation becomes.

FD Capital Group

The fourth website is www.fdcapitalgroup.co.uk.

FD Capital Group provides the wider group structure behind a network of specialist recruitment businesses.

The group originated with FD Capital, which was founded to recruit Finance Directors and CFOs on fractional, interim and permanent bases.

It has subsequently developed a wider specialist network covering finance leadership, executive leadership, non-executive appointments, qualified finance professionals and FCA-regulated senior managers.

The important point about the group model is that the specialist brands remain focused while sharing access to a wider senior candidate network.

That means a client can approach the business for one requirement and, where appropriate, access expertise from another specialist area.

For example, a growing company might need a CFO and Financial Controller.

A regulated business might need an SMF2 CFO alongside an SMF16 Compliance Officer and SMF17 MLRO.

A private-equity-backed company might require a CFO, CEO and independent Non-Executive Chair.

These are different recruitment requirements, but they can exist within the same organisation.

Why Specialisation Matters

There is a common theme running through all four businesses.

Senior recruitment is becoming increasingly specialised.

A company does not simply need someone with a particular job title.

It needs someone with the right technical background, sector experience and ability to operate within its particular environment.

For an SMF appointment, that includes regulatory accountability.

For a regulatory capital role, it includes prudential and capital expertise.

For a tax appointment, it means understanding the relevant tax discipline.

For a CFO or Finance Director, it can mean combining technical finance expertise with commercial leadership.

This is why specialist recruitment can be more effective than a generic approach.

The recruiter needs to understand the problem before trying to identify the person who can solve it.

Permanent, Interim and Fractional Appointments

Another common theme is flexibility.

Not every business needs a permanent executive immediately.

Sometimes a company needs an interim leader during a transaction, restructuring or period of rapid growth.

Sometimes a smaller business needs a CFO, Compliance Officer or other senior specialist for only one or two days a week.

And sometimes an urgent vacancy means that temporary cover is required while a permanent search is undertaken.

Fractional and interim recruitment can therefore provide businesses with access to senior expertise without immediately committing to a full-time appointment.

This can be particularly valuable for growing businesses and regulated firms.

One Network, Specialist Expertise

Ultimately, the idea behind these businesses is simple.

Specialist recruitment does not mean operating in isolation.

It means understanding a particular market deeply while still being able to draw on a wider network when a client's requirements cross disciplines.

SMF Capital focuses on FCA Senior Management Functions.

Regulatory Capital focuses on specialist regulatory and prudential finance expertise.

Tax Capital focuses on specialist tax professionals.

FD Capital Group provides the wider senior recruitment network and group structure connecting these specialist areas.

For clients, that creates a useful combination: specialist knowledge when you need it, with access to a broader senior network when the requirement spans several disciplines.

Final Thoughts

Whether your business needs an SMF16 Compliance Officer, an MLRO, a regulatory CFO, a capital specialist, a Tax Director, a Finance Director or another senior professional, the starting point should be understanding exactly what the role requires.

Technical expertise matters.

Sector experience matters.

Regulatory understanding matters.

And at senior level, judgement matters just as much.

That is the approach behind SMF Capital, Regulatory Capital, Tax Capital and FD Capital Group.

Four specialist destinations, focused on different parts of the senior recruitment market

Today we're looking at one of the most important parts of an effective compliance function: compliance monitoring.

For FCA-regulated firms, compliance monitoring is much more than a box-ticking exercise. It is the process of checking whether the business is actually complying with its regulatory obligations, following its own policies and procedures, operating effective controls and delivering the outcomes customers should receive.

SMF Capital has produced a detailed guide to the subject:

https://www.smfcapital.co.uk/compliance-monitoring-explained/

So, what does good compliance monitoring actually involve?

It Starts With Risk

The first principle is that monitoring should be risk based.

A firm should not simply create a list of reviews at the beginning of the year and repeat exactly the same programme every year.

The monitoring programme should reflect the firm's actual risks.

That means considering its regulated activities, products, customer base and distribution channels, together with complaints, breaches, previous monitoring findings, audit results, regulatory developments and changes within the business.

Higher-risk areas should generally receive more frequent and more detailed testing.

This is important because compliance monitoring is not simply about checking whether a policy exists.

A policy may say that customers must be assessed in a particular way. Monitoring needs to establish whether that process is actually followed, whether the controls work in practice and whether the resulting customer outcomes are appropriate.

Consumer Duty Has Changed Monitoring

The Consumer Duty has made this even more important for retail firms.

It is no longer enough to demonstrate that a process was followed.

Firms increasingly need evidence that customers are actually receiving good outcomes across products and services, price and value, consumer understanding and consumer support.

That means compliance monitoring may need to examine customer data, complaints, cancellation rates, arrears, call handling and other outcome information.

It also means considering whether vulnerable customers or particular customer groups are receiving worse outcomes.

In other words, monitoring needs to look beyond paperwork and establish what is actually happening.

The Three Lines

Another important consideration is the relationship between the three lines of defence.

The first line is the business itself. Advisers, operations teams, customer service and other employees own the risks and operate the day-to-day controls.

The second line is compliance and risk. This function sets standards, provides advice and independently tests whether controls are operating effectively.

The third line is internal audit, providing independent assurance over the overall framework.

Smaller firms may not have the same level of separation between these functions.

That can be perfectly reasonable if it is proportionate, but the firm needs to recognise any limitations on independence.

For example, there is an important difference between someone designing a control and someone independently testing whether that control works.

Building the Monitoring Programme

A good programme normally begins by defining the firm's compliance universe.

What

Welcome to SMF Unlocked, the podcast for anyone recruiting, holding, or thinking about taking on an FCA Senior Manager Function. I’m Adrian Lawrence, founder of SMF Capital, and every search we run is led by me personally. Today we’re focusing on one place that dominates the UK Senior Manager market more than any other: London.

If you’re hiring a Senior Manager in London – or you’re an approved person weighing up your next move in the city – this episode is for you. We’re going to look at why London is both the deepest and the most competitive pool of SMF talent in the country, how the different sectors behave, what actually works when you’re trying to secure the right person, and how we structure searches so the regulator’s fit and proper test is built in from the first conversation rather than bolted on at the end.

You can find the full written guide and contact details at the page we’re discussing today: https://www.smfcapital.co.uk/smf-recruitment-london/

Let’s start with the market itself.

London has the largest concentration of FCA and PRA-regulated firms in the UK and the deepest pool of approved Senior Managers. It is also the most competitive market for them. Banks, insurers, asset managers, market infrastructure firms, hedge funds, private equity, private wealth, payments, e-money and crypto-asset businesses all sit within a relatively small geographic area. The City and Canary Wharf house the bulk of the dual-regulated firms. Mayfair and St James’s remain the centre of gravity for much of the alternative investment and private wealth industry. Shoreditch, Old Street and King’s Cross continue to attract newer payment, e-money and crypto businesses. Both regulators are based here too – the FCA in Stratford and the PRA at the Bank of England.

That density creates opportunity and friction at the same time. London firms have access to more experienced Senior Managers than anywhere else in the country, but they are also competing with each other for the best of them. An approved Chief Risk Officer with PRA experience, or an MLRO who has taken a payments firm through authorisation, will often have several live options. The firms that hire well are the ones that move with clarity and speed, make a coherent case for the role, and present candidates to the regulator without avoidable gaps in the application.

Different parts of the London market have their own characteristics.

Banks, building societies and other dual-regulated firms carry the widest set of Senior Manager Functions and Prescribed Responsibilities. Board appointments bring PRA scrutiny of collective suitability as well as individual fitness and propriety. When we run these searches we look carefully at how a candidate will fit the existing board, not just the individual role in isolation.

Asset managers, hedge funds and private equity firms range from global houses to small MIFIDPRU firms with a handful of staff. For smaller firms the practical answer is often a combined SMF16 and SMF17 or a fractional Senior Manager arrangement. Larger firms approaching Enhanced status face a different challenge: building the risk and audit committee capability the regime expects. The difference between firm tiers matters, and we map the search to the actual regulatory expectations rather than a generic job title.

Insurance and the Lloyd’s market form another distinct ecosystem. Managing agents, carriers and MGAs each need Senior Managers with genuine market experience. Dual-regulated insurers answer to both regulators, so the search has to reflect that dual scrutiny.

Fintech, payments and crypto-asset firms generate a steady flow of first-time authorisation cases. Their initial Senior Manager appointments often determine whether an application succeeds. Founders need people the regulator can rely on – especially around safeguarding, financial crime and the FCA’s approach to newer business models. We spend a lot of time helping pre-authorisation firms assemble credible teams rather than simply filling vacancies at the last minute.

Overseas firms opening UK branches almost always choose London. The SMF19 Head of Third Country Branch has to reassure the regulators about a business with no UK track record. That requires a particular combination of regulatory credibility and commercial judgement.

In London the question is rarely whether suitable Senior Managers exist. It is whether you can identify and secure the right one before another firm does, and then present them cleanly to the regulator.

That brings us to how we actually run an SMF search in London.

The core method is the same wherever the firm is based, because the regulator’s test is the same. What changes by location is the candidate market, the competing employers and the pay expectations. Local knowledge matters.

We start from the Statement of Responsibilities the new Senior Manager will sign and any Prescribed Responsibilities they will carry. The specification is built around those documents rather than around a conventional job title. We approach candidates directly and in confidence – most of the people we speak to are not actively looking. Before anyone reaches a shortlist we test them against what the approval application will ask: prior approvals, regulatory history, directorships and financial soundness, measured against the fit and proper test. We also start regulatory references early. A late reference remains one of the most common causes of delay in the process.

I interview every shortlisted candidate personally. We stay involved until the individual is approved and in post. The full service covers permanent, interim and fractional appointments across board and executive roles, control functions, and firm structure work including team builds, tier changes, governance reviews and overseas firm support.

A few practical realities of London hiring are worth spelling out.

Pay is the highest in the UK. Packages at larger firms usually include variable remuneration subject to regulatory deferral and clawback. Smaller firms rarely win on base salary alone. They win on scope, equity, flexibility and the chance to build a function. We give clients an honest view of where their package sits before the search starts so offers do not fail at the final stage.

Notice periods for Senior Managers in London commonly run three to six months. The regulator can take up to three months to decide a complete application. When these timelines are planned together they can run in parallel. When they are planned separately they can push a start date back by half a year. If a Senior Manager leaves unexpectedly, the 12-week rule allows temporary cover. Since the April 2026 reforms the firm must submit an application within that period if the person covering is to continue. We can provide interim cover and run the permanent search at the same time.

The designations we see most frequently in London mandates are compliance oversight and MLRO roles, Chief Risk Officers, Chairs and independent committee chairs, and Chief Operations holders at firms focused on operational resilience. You can check any candidate’s current approvals on the FCA Financial Services Register before interview.

Under the Senior Managers and Certification Regime each Senior Manager answers personally for their area. London candidates understand this well. The strongest ones ask hard questions about governance, resourcing and their predecessor’s departure before accepting. Firms that answer those questions openly tend to hire better.

A few questions we hear regularly:

Do we only recruit London-based Senior Managers for London firms? No. Many London firms now accept hybrid working, which widens the pool to candidates across the South East and beyond. We search wherever the right candidate is, within the attendance pattern the role needs.

How quickly can we shortlist for a London SMF role? A typical shortlist takes three to five weeks, depending on the designation and how specialist the sector experience needs to be. Interim cover can often be arranged sooner.

Can we help a London firm that has not yet been authorised? Yes. Pre-authorisation firms form a significant part of our London work.

Do we recruit for PRA-designated Senior Manager roles? Yes. We work with dual-regulated banks and insurers where appointments need PRA as well as FCA approval.

SMF Capital was founded by me, Adrian Lawrence FCA. I am a Chartered Accountant and Fellow of the ICAEW, a former listed-company Finance Director, and I lead every SMF search personally, including those for London firms. I interview every shortlisted candidate myself.

If you are recruiting a Senior Manager in London, or you are an approved person considering a move into or within the city, the practical next step is straightforward. Tell us the designation, the firm type and your timing. We will come back to you the same working day, with the fit and proper assessment built into the search from the first conversation.

The full page with more detail on London’s SMF market, sector nuances, process and services is here: https://www.smfcapital.co.uk/smf-recruitment-london/

Thank you for listening to SMF Unlocked. If this episode was useful, share it with a colleague who is hiring or considering an SMF role. Detailed written guides to every Senior Manager Function and the wider SMCR framework are available at smfcapital.co.uk. Until next time.