SMF Recruitment for FCA-Regulated Firms
Senior Manager Function Recruitment, With the Regulator’s Test Built In
SMF Capital recruits Senior Manager Function holders for UK regulated firms, covering executive, non-executive, permanent, interim and fractional appointments. Every search is built around the regulator’s fit and proper assessment from the first conversation, and every search is led personally by Adrian Lawrence FCA.
We work with wealth and investment managers, consumer credit lenders, insurers and intermediaries, banks and building societies, payments, fintech and crypto-asset firms, and overseas firms establishing UK branches. From a first compliance appointment ahead of authorisation to a full board refresh at an Enhanced firm, we run the search on the regulator’s timetable as well as yours.
SMF Recruitment Services
Most firms come to us with one of a handful of problems. Each has its own dedicated page setting out how we approach it, what it typically costs in time, and where the regulatory pressure points sit. If you’re not sure which applies, tell us about your hire and we’ll point you in the right direction.
SMF Recruitment Services
Permanent executive and non-executive searches for any Senior Manager Function, with the fit and proper assessment built into every stage.
Our SMF search service →Fractional & Interim SMF Cover
Experienced SMF holders available at short notice to cover a vacancy, bridge an approval period or serve a smaller firm part-time.
Interim and fractional cover →SMF Authorisation Support
Assembling the Senior Managers an FCA authorisation application needs, so the people named on the application can carry it.
Authorisation support →Governance & SMF Structure Review
An independent look at your Responsibilities Map, allocation of Prescribed Responsibilities and the fit of your current SMF holders.
Structure review →Multi-SMF Board & Executive Team Build
Coordinated searches for several Senior Managers at once, typically for firms moving from Core to Enhanced or building a new board.
Team build →Overseas Firms & UK Branches
SMF19 Head of Third Country Branch searches and group SMF structuring for overseas firms operating in the UK.
Overseas firm support →Retained Executive Search
A structured, retained search for board, executive and hard-to-fill Senior Manager roles, with market mapping and regular reporting.
Retained search →See recent appointments in our case studies.
Recruitment by Role
The Senior Manager Functions firms hire most often each have a dedicated page covering what the regulators expect, permanent, interim and fractional options, what we look for in candidates and how the approval process works. For every other function, see the complete SMF designations guide.
Compliance Officer (SMF16)
The most frequently recruited Senior Manager Function: permanent, interim and fractional compliance oversight across every sector, including the compliance monitoring programme the role owns.
Compliance officer recruitment →MLRO (SMF17)
SMF17 holders and MLROs at payments, e-money and crypto firms, with financial crime experience matched to your risks.
MLRO recruitment →Compliance Officer and MLRO (SMF16 and SMF17)
One experienced person holding both functions, full-time or fractional: the structure most smaller regulated firms use.
Combined role recruitment →Chief Risk Officer (SMF4)
Independent risk leadership for banks, insurers and investment firms, including the ICARA, ORSA and ICAAP.
CRO recruitment →Chair & Committee Chairs (SMF9–SMF14)
Chairs, risk, audit, remuneration and nomination committee chairs, and Senior Independent Directors.
Board recruitment →Chief Operating Officer (SMF24)
Operations, technology and operational resilience leadership, including outsourcing and cyber oversight.
COO recruitment →Regulated Chief Executive (SMF1)
Chief executives for regulated firms, with regulator interviews and approval planned into the search.
Regulated CEO recruitment →Chief Financial Officer (SMF2)
CFOs for banks, insurers and dual-regulated firms, with capital, liquidity and regulatory reporting experience.
CFO recruitment →Executive Director (SMF3)
Finance, operations and commercial directors joining the board of a regulated firm, approved before they take their seat.
Executive director recruitment →Head of Internal Audit (SMF5)
Independent internal audit leaders who report to the audit committee and can challenge the executive.
Internal audit recruitment →Senior Business Heads (SMF18)
Heads of business lines and functions at Enhanced firms, banks and insurers who need approval in their own right.
SMF18 recruitment →Head of UK Branch (SMF19)
Branch heads for overseas banks and insurers operating in the UK, bridging the UK regime and head office.
Branch head recruitment →Financial Crime Leadership
Heads of financial crime, deputy MLROs and the team around your MLRO, from screening to investigations.
Financial crime recruitment →Fractional, Interim and Urgent Cover
Not every firm needs a full-time Senior Manager, and not every vacancy can wait for a three-month search. These pages cover part-time, interim and urgent appointments for compliance officers, MLROs and other Senior Managers.
Fractional MLRO
Experienced, approvable MLROs working one to three days a week for payments, crypto, wealth and smaller firms.
Fractional MLRO recruitment →Part-Time Compliance Officer
Approved SMF16 compliance leadership for small FCA-regulated firms, from one day a week.
Part-time compliance officer →Interim MLRO & Compliance Officer
Interim SMF16 and SMF17 cover for vacancies, remediation and skilled person reviews, shortlisted in days.
Interim recruitment →Urgent SMF Replacement
A Senior Manager has just left. Interim cover fast, the regulatory steps handled and a permanent search in parallel.
Urgent replacement →Every Senior Manager Function, Executive and Non-Executive
The Senior Managers and Certification Regime attaches named individuals to defined functions, each set out in SUP 10C of the FCA Handbook. We recruit across the full range, from the Chief Executive and Chair through to the control functions and the less familiar designations firms still have to get right. Our designation guides explain what the regulator expects from each role and what separates a candidate who will be approved from one who will struggle.
Not sure which designation a role should carry? Read SMF3 or SMF18? Getting the designation right before you recruit, or browse the complete SMF designations guide.
Why SMF Hiring Needs a Specialist
An SMF appointment is not a job title with a form attached at the end. The individual cannot start in the function until the regulator has approved them, and approval turns on whether they meet the fit and proper test: honesty, integrity and reputation; competence and capability; and financial soundness. Once approved, they carry personal accountability for the areas set out in their Statement of Responsibilities, and under the Duty of Responsibility the regulator can take action against them if a breach happens in their area and they did not take reasonable steps to prevent it.
That changes what a good search looks like. A generalist process finds a strong candidate, makes an offer and then hands the regulatory application to the compliance team. By that point the firm has committed to someone the FCA or PRA may question, often on points that could have been spotted in the first interview. We work the other way round. We test candidates against what the approval application will ask before anyone reaches a shortlist, and we request regulatory references early rather than after an offer is accepted. Our guide to what goes wrong in Form A submissions shows why that matters.
We also don’t treat “FCA-regulated experience” as one portable credential, because it isn’t. An MLRO from a retail bank is not automatically ready for a crypto-asset firm. A risk committee chair who has overseen an insurer’s solvency framework may not know a MIFIDPRU investment firm’s capital rules. A Chief Executive who ran a Core firm may not be ready for the prescribed responsibilities that come with Enhanced status. Every search we run is specified against the regulatory context the role actually carries, not a generic seniority bar.
How SMF Capital Works
Every mandate follows the same sequence, adjusted for the designation, the firm’s tier and whether the appointment is permanent, interim or fractional. A short call is enough to start; we don’t ask for a lengthy written brief before beginning.
- Brief against the Responsibilities Map. We start from the Statement of Responsibilities the new SMF holder will sign and the Prescribed Responsibilities they will carry, then build the role specification around them. Our guide to the Responsibilities Map explains how the pieces fit together.
- Targeted search, including passive candidates. Most strong SMF candidates are not job-hunting. We approach them directly and in confidence, without naming the client until the right point in the process.
- Fit and proper pre-assessment. Before a shortlist is presented, we test each candidate against the areas the approval application will cover, including prior approvals, regulatory history, directorships and financial soundness.
- Shortlist and interviews. You meet a small number of candidates who have already been tested for regulatory readiness as well as commercial fit. Adrian Lawrence FCA interviews every shortlisted candidate personally, and our guide to interviewing an SMF candidate sets out the questions that reveal readiness.
- Regulatory references and application support. We help you gather regulatory references covering the previous six years and prepare the Statement of Responsibilities and supporting information the application needs.
- Through approval to day one. We stay involved until the regulator has approved the individual and they are in the role, including managing notice periods around the approval timetable.
For a realistic view of how long each stage takes, read our guide to how long an SMF appointment actually takes.
SMF Designations We Recruit For
Four practice areas cover every Senior Manager Function. Every SMF search is led personally by Adrian Lawrence FCA
Board & Non-Executive
Chairs, Senior Independent Directors and the committee chairs who oversee risk, audit and remuneration.
→ SMF9 Chair of the Governing Body → SMF12 Remuneration Committee Chair → SMF13 Nomination Committee ChairBoard designation guides →
Executive Leadership
The Chief Executive, Chief Operations and Executive Director functions that carry overall accountability for the firm.
→ SMF1 Chief Executive → SMF24 Chief Operations → SMF3 Executive DirectorSenior Manager Functions explained →
Control Functions
Risk, internal audit, compliance oversight and money laundering reporting: the functions that tell the board what it needs to hear.
→ SMF4 Chief Risk Function → SMF16 Compliance & SMF17 MLRO → The MLRO role explainedInterim control function cover →
Firm Structure & Branches
New authorisations, tier changes and overseas firms setting up or reorganising their UK presence.
→ SMF authorisation support → SMF approval for overseas firmsGovernance structure review →
Every SMF search is led personally by Adrian Lawrence FCA
Specialist SMF Recruitment by Sector
The designations are the same across the regime, but the candidate market for each sector is not. A compliance officer who excels at a wealth manager may struggle at an MGA, and a CRO from a bank may not know a MIFIDPRU firm’s capital rules. Each sector page sets out the functions that apply, where the regulator focuses and the roles we recruit.
Wealth Managers & Advice Firms
Chief executives, compliance officers, MLROs and CASS oversight for wealth managers, discretionary managers and advice firms, including consolidators.
Sector page →Investment Managers & Hedge Funds
Senior Managers for MIFIDPRU firms, from boutiques and LLPs to larger managers, with the prudential and conflicts expertise the ICARA demands.
Sector page →Consumer Credit Firms
Executive, compliance and risk leaders for lenders, brokers and debt collectors who can evidence good customer outcomes, including during remediation.
Sector page →Insurers, Brokers & MGAs
Solo-regulated brokers and MGAs and dual-regulated insurers, with product governance and fair value at the centre of every search.
Sector page →Banks & Building Societies
PRA and FCA-designated appointments for smaller banks, specialist lenders and building societies, planned around board collective suitability.
Sector page →Payments, E-Money & Fintech
Compliance, MLRO and senior leadership for payments and fintech firms, and Senior Managers where the firm also holds FSMA permissions.
Sector page →Crypto-Asset Firms
Senior teams for crypto-asset firms moving from registration to full FCA authorisation, where the people named in the application matter most.
Sector page →Firms Seeking FCA Authorisation
New firms assembling the Senior Managers an application needs, planned around the submission date and the regulator’s threshold conditions.
Authorisation support →A note on payments: most payment and e-money institutions are authorised under the Payment Services or Electronic Money Regulations rather than FSMA, so the Senior Managers regime applies only where the firm also holds FSMA permissions. The FCA still assesses their directors and managers closely, and the MLRO carries real weight. Our payments and fintech page explains the difference.
SMF Recruitment Across the UK
We work with regulated firms across the country, and run dedicated searches in the UK’s main financial centres. Each location page covers the local candidate market, the firm types concentrated there and how hiring works in practice.
SMF Recruitment London
The deepest pool of approved Senior Managers in the UK, and the most competitive market for them, across banks, asset managers, Lloyd’s and fintech.
London →SMF Recruitment Birmingham
The largest financial services sector outside London, with banking, consumer credit, motor finance, payments and insurance across the West Midlands.
Birmingham →SMF Recruitment Bristol
A leading cluster of wealth management, investment platform and insurance firms, and a growing fintech sector across the West of England.
Bristol →SMF Recruitment Manchester
The largest financial centre outside London, with consumer credit, wealth, insurance and fintech firms across the North West.
Manchester →SMF Recruitment Edinburgh
Scotland’s financial centre, with asset managers, life and pensions insurers, banks and a growing fintech sector.
Edinburgh →SMF Recruitment Leeds
Building societies, consumer credit and debt businesses, insurers and wealth managers across Leeds and Yorkshire.
Leeds →Regulated Hiring Is Different
The Fractional and Interim Advantage
Many smaller authorised firms don’t need a full-time compliance officer, MLRO or chief risk officer. A fractional SMF holder working one or two days a week often gives the right level of oversight at a cost proportionate to the firm. Our network includes experienced SMF holders who have chosen portfolio work deliberately and bring larger-firm experience to smaller firms. Read when interim and fractional appointments work, and when they don’t.
Working to the Regulator’s Timetable
A complete approval application can take up to three months to be decided, and gaps or questions extend that. Since the April 2026 SMCR reforms, a firm covering an unexpected vacancy has 12 weeks to submit an application for the person covering the role, rather than 12 weeks to have them approved. We plan each search around those timings so regulatory approval does not become the thing that delays the start date.
Discretion and Senior Oversight
Senior Manager searches are confidential by nature. A departing Chief Risk Officer or a board refresh is sensitive inside the firm and with its supervisor. We approach passive candidates without naming the client until the right point, and Adrian Lawrence FCA is involved directly on every mandate rather than handing it to a junior consultant.
Knowledge Centre
Reference guides to the rules and mechanics behind every SMF appointment, written for the boards, compliance teams and candidates who have to apply them.
The Fitness and Proper Test in Full
Every criterion behind the regulator’s three-part assessment, and how it is applied in practice.
→ Read the guideRegulatory references →
Which SMFs Apply at Which Firm Tier?
A designation-by-designation map across Limited Scope, Core and Enhanced firms.
→ Read the guideThe Responsibilities Map →
The 12-Week Rule
How firms cover an unexpected Senior Manager vacancy after the April 2026 reforms.
→ Read the guideNotification forms B to E →
Compliance Monitoring Explained
How to build and run a risk-based monitoring programme, and what the board should see from it.
→ Read the guide → Conduct Rules explainedFull Knowledge Centre →
New in the Knowledge Centre: the SMCR glossary, suspicious activity reports, customer due diligence, the business-wide risk assessment, failure to prevent fraud and the Duty of Responsibility.
Insights
Analysis of regulatory developments, enforcement patterns and how SMF searches actually run.
FCA Enforcement Trends
What recent enforcement action shows about how the regulator assesses “reasonable steps”.
→ Read the analysisConsumer Duty and the SMF framework →
Building an SMF Team From Scratch
The authorisation journey and the Senior Managers an application needs.
→ Read the analysisForm A mistakes →
Operational Resilience
Where supervisory expectations actually stand, and what it means for SMF24 holders.
→ Read the analysisThe Certification Regime →
SMF Capital Blog
Practical articles on structuring and filling compliance, MLRO and financial crime roles.
→ When to split a combined SMF16/17 role → Do you need a deputy MLRO?Visit the blog →
For SMF Candidates
If you hold a Senior Manager Function, or you are ready for your first one, we want to hear from you. Many of the roles we fill are never advertised, and many of the strongest appointments go to candidates we already know. Registration is confidential, and we will never share your details with a firm without speaking to you first.
Every role we’re currently recruiting, from compliance officers and MLROs to chief operations, chief risk and board appointments, permanent, interim and fractional, is listed on our SMF jobs board. If nothing there fits right now, register as a candidate and we’ll contact you when a suitable role comes up. We’re particularly interested in experienced compliance officers and MLROs open to fractional or interim work, risk and audit committee chairs, and executives who have taken a firm through authorisation or a move to Enhanced status.
To check your own approval history before you apply, the FCA Financial Services Register shows the functions you are currently approved to perform. For a sense of the market, read what SMF roles actually pay in 2026.
Podcast, Events and Media
We share what we learn from SMF searches through our podcast, SMF Unlocked, available on Apple Podcasts, Spotify and other major platforms, and through free online briefings, round tables and candidate clinics. See upcoming dates on our events page, or visit the media centre for every podcast platform, press coverage and media enquiries.
Part of a Specialist Recruitment Network
SMF Capital is one of five specialist practices, each focused on a different tier of senior appointment. Every search is led personally by Adrian Lawrence FCA
FD Capital
Fractional, interim and permanent Finance Directors and CFOs, including SMF2 appointments.
→ fdcapital.co.ukSMF2 CFO recruitment →
Exec Capital
C-suite and board-level executive search across the UK, including regulated firms.
→ execcapital.co.ukFCA-regulated executive search →
NED Capital
Non-executive directors, chairs and governance appointments for boards of every size.
→ nedcapital.co.ukNon-executive search →
Accountancy Capital
Qualified finance professionals below director level, including CASS and regulatory reporting roles.
→ accountancycapital.co.ukQualified finance recruitment →
Where a search doesn’t carry an SMF designation, we will say so and make the introduction ourselves.
About Our Founder
SMF Capital was founded by Adrian Lawrence FCA, a Chartered Accountant and Fellow of the ICAEW who holds a practising certificate in his own name. He holds a BSc from Queen Mary College, University of London, and is a former listed-company Finance Director. He founded FD Capital in 2018 and has since built Exec Capital, NED Capital, Accountancy Capital and SMF Capital to give firms specialist coverage at every tier of senior appointment.
Adrian has worked on regulated-firm appointments across payments, investment management, insurance and consumer credit, and he personally interviews every shortlisted SMF candidate. Having sat on both sides of the table, as a finance director answering to a board and as a recruiter advising one, he knows how much of an SMF appointment depends on questions a standard recruiter never asks. View Adrian’s ICAEW profile.
Published research
Frequently Asked Questions
What is a Senior Manager Function?
A Senior Manager Function is a role the FCA or PRA has designated as carrying the most significant responsibility within a regulated firm. Anyone performing one must be approved by the regulator before they start, must have a Statement of Responsibilities, and is subject to the Senior Manager Conduct Rules and the Duty of Responsibility. Our guide to Senior Manager Functions explained covers each designation.
How long does it take to appoint an SMF?
Allow for the search itself, the candidate’s notice period and the regulatory approval period, which can run to three months once a complete application is submitted. Many of these steps can run in parallel if they are planned from the start. Our SMF appointment timeline sets out each stage.
Can we appoint an interim while approval is pending?
Where an SMF holder leaves unexpectedly, a firm can use the 12-week rule to have someone perform the function temporarily. Following the April 2026 reforms, the firm must submit an approval application within those 12 weeks if the person is to continue, and the Senior Manager Conduct Rules apply to the person covering. We can provide interim cover and run the permanent search at the same time.
Do you recruit SMF2 Chief Finance Officers?
Yes. See our page on Chief Financial Officer recruitment (SMF2) and our SMF2 guide. Our sister practice FD Capital also places fractional and interim finance directors, and our article on why an SMF2 search should start with a CFO recruiter. Where a firm is appointing several Senior Managers at once, we coordinate the searches across the network.
Does the Senior Managers regime apply to payment and e-money firms?
Only where the firm also holds FSMA permissions. Firms authorised solely under the Payment Services or Electronic Money Regulations aren’t within the regime, but the FCA still assesses their directors and managers, and they need an MLRO under the Money Laundering Regulations. See our payments and fintech page.
Can one person hold more than one SMF?
Often, yes, particularly in smaller firms where the compliance oversight and MLRO functions are commonly combined. Some combinations are not appropriate, for example where one role is meant to provide independent challenge to another. Our governance and SMF structure review looks at how responsibilities are allocated across your Senior Managers, and our compliance officer and MLRO recruitment pages explain how we handle combined roles.
Where can I see your current SMF jobs?
All current roles are on our SMF jobs board. Candidates can also register confidentially to hear about roles before they’re advertised.
Latest SMF Roles
Fractional Compliance Officer and MLRO (SMF16/SMF17) – Small FCA-Authorised Broker, Midlands
Location: Midlands, hybrid (mainly remote with periodic on-site days) Commitment: Fractional, 1 day a week Day rate: £500–£800 per day, depending on…
View role →Fractional MLRO – First-Time UKGC Remote Gambling and Betting Licence
Location: UK, remote Commitment: Fractional, around 1 day a week (10–20 hours a week during the application) Day rate: £700–£1,000 per day…
View role →Senior compliance manager SMF16 SMF17 consumer finance East Midlands
Location: East Midlands (hybrid: on-site and remote) Type: Permanent; interim or fractional considered Salary: £70,000–£90,000 depending on experience Functions: SMF16 Compliance Oversight…
View role →Recent Posts
Recruiting for a Senior Manager Function?
Tell us the designation, the firm type and your timing. We will come back to you the same working day, and we build the fit and proper assessment into the search from the first conversation.
Adrian Lawrence FCA