SMF Authorisation Support

Applying for FCA authorisation means building an entire senior management structure from nothing — and the sequencing of who you recruit, and when, has a direct effect on how smoothly your application actually moves through the FCA. SMF Capital works with authorising firms, particularly in fintech, payments and cryptoassets, to build a credible SMF team ahead of submission rather than as an afterthought once the application is already drafted.

Why Sequencing Is the Whole Problem

The FCA doesn’t authorise a business plan in the abstract — it authorises a firm with named, individually assessed senior managers already largely in place. Firms that build out their commercial team first and treat SMF16, SMF17 and board governance as a late-stage step consistently present weaker applications than firms that identify strong, specific compliance and financial crime leadership early, even while other parts of the team are still forming.

What We Help You Build

A credible, named Compliance Oversight function

We identify and assess SMF16 candidates specifically against your business model and regulatory permissions, so your application names a genuinely capable individual rather than describing a role you intend to fill eventually.

MLRO identification proportionate to your financial crime risk

For firms with meaningful financial crime exposure — payments, e-money, cryptoasset businesses especially — we identify SMF17 candidates with direct experience in a comparable risk profile, strengthening the application considerably compared with a generic assurance about future AML processes.

Board and chair structure proportionate to your scale

Where a chair or independent non-executive presence is expected, we help identify and engage that individual ahead of submission, working alongside our sister practice Exec Capital where a genuinely board-level appointment is needed.

Specifically drafted Statements of Responsibilities

We help make sure the governance documentation submitted alongside your named individuals reflects a genuinely thought-through structure, not a generic template — a factor the FCA weighs directly in assessing whether your overall governance has been properly considered.

Fractional and Interim Cover Through the Authorisation Period

Many authorising firms use fractional or interim SMF16/17 arrangements specifically through the application period and early months of trading, scaling to a full-time hire once volume genuinely justifies it. We place specialists with direct authorisation experience specifically, since guiding a firm through the process itself is a distinct skill from running an established function — see our dedicated fractional and interim cover service for more detail.

Our Approach

We start by understanding your authorisation timeline and business model, then work backwards to identify exactly which SMF designations you’ll need, in what order they should be secured, and where fractional or interim cover makes sense as a bridge to full-time hires post-authorisation. This is a genuinely different exercise from a standard recruitment brief — it’s sequencing a whole governance structure against a regulatory submission deadline, not filling one role at a time.