Can a Senior Manager Work Remotely or From Overseas?
Remote and hybrid working is now normal across financial services, and candidates for Senior Manager roles increasingly ask about it at first interview. Firms are often unsure how far they can go. Can a compliance officer work from home most of the week? Can a chief executive relocate abroad? Can an MLRO be based outside the UK? There is no single rule that answers all of these, but there are clear principles, and a few roles where location matters a great deal. This guide sets them out from the hiring side, so firms can offer flexibility without creating a regulatory problem.
The Short Answer
Remote and hybrid working within the UK is generally compatible with holding a Senior Manager Function, provided the person can genuinely perform the role and take reasonable steps over their responsibilities. Being based overseas is a different question. It can be acceptable for some roles, particularly group and non-executive roles, but for UK firms the regulator expects the people who run the firm day to day to be in a position to do so from the UK. For some functions, such as the MLRO, the expectation of a UK presence is strong.
What the Regulator Is Actually Concerned About
The SMCR doesn’t contain a general rule about where Senior Managers must sit. The concerns come from the wider framework:
- Location of the firm’s management. The Threshold Conditions on location of offices require a UK-incorporated firm to have its head office in the UK. The regulator reads “head office” as the place where the central management and control of the firm sits, not just a registered address. If the people who run the firm are mostly abroad, that becomes a question about whether the firm meets the condition.
- Effective oversight. Every Senior Manager must take reasonable steps to prevent breaches in their area, under the Duty of Responsibility and the Senior Manager Conduct Rules. If distance or working pattern makes oversight weaker, that is a problem whatever the formal arrangements say.
- Availability to the regulator. Senior Managers need to be available for supervisory meetings, interviews and, when things go wrong, at short notice.
- Systems and controls. SYSC requires firms to have robust governance, including arrangements that work for remote staff: secure access, record keeping, supervision and data protection.
Remote and Hybrid Within the UK
For most Senior Manager roles, working from home for part or most of the week is now unremarkable. The test is whether the role is performed effectively. Firms that make it work tend to have:
- a clear expectation of time in the office or on site, especially for board meetings, committee meetings and key team events
- systems that give the Senior Manager full access to management information, case systems and monitoring outputs remotely
- compliant arrangements for recording communications where the role requires it
- regular, documented contact with their teams and the business areas they oversee
- an escalation route that works quickly, wherever people are
- a working pattern that is recorded and taken into account in the annual fitness and propriety assessment
Remote working matters most in roles that depend on influence and visibility. A compliance officer who never sees the business in person may find it harder to build the relationships that make challenge effective. That doesn’t rule out a largely remote arrangement, but it should be a conscious decision, not a default.
Being Based Overseas
Overseas arrangements need more care, and the answer depends heavily on the role.
| Role | Overseas base | Notes |
|---|---|---|
| Executive Senior Managers running a UK firm (SMF1, SMF3, SMF24) | Difficult | Raises questions about where the firm’s central management sits; regulator likely to want a strong UK presence |
| Compliance oversight (SMF16) | Difficult | Hard to oversee a UK business effectively from abroad; regulator will want to understand how it works |
| MLRO (SMF17) | Generally not acceptable | Industry guidance from the JMLSG expects the MLRO to be based in the UK, and the nominated officer has legal duties to the National Crime Agency |
| Group Entity Senior Manager (SMF7) | Often acceptable | The role exists for group executives who influence the UK firm, often from abroad; see SMF7 explained |
| Non-executive roles (SMF9 to SMF14) | Possible | Overseas NEDs can work, if they can commit the time and attend meetings; see NED time commitment |
| Heads of third-country branches (SMF19) | Role-specific | Branch arrangements bring their own expectations; see overseas firms and group structures |
A temporary period working abroad, such as a few weeks a year, is different from a permanent overseas base. Short periods are usually manageable with the right systems and access. A permanent move is a material change that the firm should consider carefully, and may need to discuss with its supervisor.
Scenario: An investment firm’s SMF16 asks to relocate to Spain and work remotely full time. The firm considers whether the compliance function can still be overseen effectively, whether the move affects where the firm’s management sits, and what the tax and employment position would be. It agrees a hybrid arrangement instead: the compliance officer spends one week a month in London, covering all board and risk committee meetings, with a UK-based deputy handling day-to-day matters. The firm records the decision, updates the Statement of Responsibilities and reviews the arrangement after six months.
Practical Issues Beyond Regulation
Regulatory acceptability is only part of the picture. An overseas arrangement can also create:
- Tax risk, including the possibility that a senior person working from another country creates a taxable presence for the firm there;
- Employment law issues, because local employment law may apply to someone working in another country;
- Data protection questions, particularly around access to customer data from outside the UK; and
- Insurance gaps, where policies assume the insured person works in the UK.
Take specialist advice before agreeing any long-term overseas arrangement for a Senior Manager.
Recruiting for a Remote or Flexible SMF Role
Offering flexibility can widen the candidate pool considerably, particularly for firms outside London. Many strong candidates in Birmingham, Bristol, Manchester and elsewhere will consider a role in a city they would never commute to five days a week. Our city pages for Birmingham, Bristol and London show how location affects the market.
When recruiting, be specific about what flexibility means. “Hybrid” means different things to different people. State expected days on site, board and committee commitments, travel and any limits on working abroad. A clear statement avoids misunderstandings after the offer and makes it easier to show the regulator that the role was designed to be performed properly.
Fractional Senior Managers are a related case. Many work for more than one firm and largely remotely. That can work well for smaller firms, provided the time commitment is realistic and the Senior Manager can respond when needed. Our guide to when interim and fractional appointments work covers the issues.
Checklist Before Agreeing a Remote or Overseas Arrangement
| Question | What to record |
|---|---|
| Can the person take reasonable steps over every responsibility from this location? | How oversight works in practice, and the information they receive |
| Does the arrangement affect where the firm’s management sits? | The location of the other Senior Managers and where key decisions are taken |
| Will they attend board and committee meetings? | Expected attendance in person and remotely |
| Can they be reached quickly in an emergency? | Escalation arrangements and deputies |
| Are systems, records and data access compliant? | IT, recording and data protection sign-off |
| Have tax, employment and insurance been checked? | Advice received and any conditions |
| Does the regulator need to know? | Whether the change is material and any discussion with the supervisor |
Flexible SMF Appointments
Remote, hybrid, fractional and overseas-group roles. Every SMF search is led personally by Adrian Lawrence FCA
Fractional and Interim
Flexible Senior Manager cover.
→ Fractional and interim cover
→ Fractional or full-time?
Overseas and Group
Cross-border structures.
→ Overseas firms support
→ Group SMF roles
Control Functions
Compliance and MLRO searches.
→ Compliance officer (SMF16)
→ MLRO (SMF17)
Every SMF search is led personally by Adrian Lawrence FCA
Frequently Asked Questions
Can a compliance officer work from home?
Yes, for part or most of the week, provided they can oversee the function effectively, have the systems and information they need, and attend key meetings. The arrangement should be a deliberate decision and recorded.
Can an MLRO be based outside the UK?
Generally not. Industry guidance expects the MLRO to be UK-based, and the nominated officer’s legal duties to the National Crime Agency make a UK presence important.
Can a non-executive director live abroad?
Often, yes, provided they can commit the time, attend meetings and be available when needed. Many regulated boards include overseas-based NEDs.
Do we need to tell the FCA if a Senior Manager moves abroad?
If the change is material to how the firm is run or how the role is performed, it is sensible to consider whether to discuss it with your supervisor. Take advice on your firm’s position.
Does a remote role affect FCA approval?
The regulator may ask how the role will be performed. A clear description of the working pattern, attendance and oversight arrangements helps.
Do you recruit for remote and hybrid SMF roles?
Yes. We recruit for remote, hybrid and fractional Senior Manager roles, and can advise on how to structure the role so it works for the candidate and the regulator.
About the Author
Adrian Lawrence FCA is the founder of SMF Capital. He is a Chartered Accountant and Fellow of the ICAEW, holds a practising certificate in his own name, and is a former listed-company Finance Director with a BSc from Queen Mary College, University of London. He founded FD Capital in 2018 and has since built a network of five specialist recruitment practices, including NED Capital for non-executive appointments. He leads every SMF Capital search personally, including remote, hybrid and fractional Senior Manager roles. View Adrian’s ICAEW profile.
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Adrian Lawrence FCA is the founder of SMF Capital and a Fellow of the Institute of Chartered Accountants in England and Wales and holds an ICAEW practising certificate in his own name. He holds a BSc from Queen Mary College, University of London, and has over 25 years of experience working with boards, investors and business owners across the UK. He founded SMF Capital to help FCA and PRA-regulated firms appoint the Senior Managers the regulators expect, with the fit and proper assessment built into every search, and personally leads every Senior Manager Function search.
