Writing an SMF Job Description That Works
A job description for a Senior Manager role does more work than most. It attracts or deters candidates, it shapes the interview, and it should line up with the Statement of Responsibilities the regulator will see with the Form A. Yet many SMF job descriptions are recycled from a previous hire or a generic template, with the regulatory content bolted on at the end. This guide explains what a good job description for a compliance officer, MLRO or other Senior Manager role should contain, how it relates to the Statement of Responsibilities, and the mistakes that cost firms good candidates.
Job Description and Statement of Responsibilities: Different Documents, Same Role
Every Senior Manager must have a Statement of Responsibilities, which sets out what they are accountable for under the regime and is submitted to the regulator. The job description is an employment document: it describes the role, the reporting lines, the skills and experience needed and what the person will do day to day. The two are different, but they must be consistent.
| Job description | Statement of Responsibilities | |
|---|---|---|
| Purpose | Recruitment, employment and performance management | Regulatory record of what the Senior Manager is accountable for |
| Audience | Candidates, HR, the hiring panel | The FCA or PRA, the firm’s board, the Senior Manager |
| Content | Duties, skills, experience, reporting lines, package, location | Senior Manager Functions, Prescribed Responsibilities, other responsibilities |
| Style | Readable and persuasive | Precise, consistent with the responsibilities map |
| Risk if wrong | Wrong candidates apply; good ones don’t | Unclear accountability; delays to approval; problems if things go wrong |
A sensible approach is to draft the Statement of Responsibilities first, using our Statement of Responsibilities template, then build the job description around it. That way, every accountability in the SoR is reflected in the duties, and nothing in the job description implies an accountability the SoR doesn’t give.
What a Good SMF Job Description Contains
- The role and the function. Name the job title and the Senior Manager Function, such as SMF16 compliance oversight or SMF17 money laundering reporting. Say clearly that the role requires regulatory approval. See our guide to SMF designations if the function isn’t obvious.
- The firm and why the role exists. Describe the firm’s regulated activities, size, customers and stage. Explain whether the role is new, a replacement or part of growth. Candidates need this to judge whether their experience fits.
- Reporting lines and governance. Who the role reports to, which committees it sits on, whether it has direct access to the board or chair, and who reports to it.
- Accountabilities. The main areas of responsibility, consistent with the SoR, including any Prescribed Responsibilities.
- Day-to-day duties. What the person will actually do: monitoring plans, reports to the board, regulatory contact, team leadership, projects.
- Experience and skills. What is essential and what is desirable. Be specific about sector experience where it matters.
- Working pattern and location. Expected time on site, attendance at board meetings and any flexibility.
- Package. At least a range for salary, plus bonus, benefits and any constraints on variable pay.
- Process and timing. The stages, who will be involved and the regulatory approval step.
Examples: Compliance Officer and MLRO
The two most common SMF job descriptions we see are for compliance officers and MLROs. Here is what the accountability section of each typically needs to cover.
Compliance officer (SMF16)
- Oversight of the firm’s compliance with FCA rules, as set out in SYSC 6.1
- A risk-based compliance monitoring programme and reporting its results to the board
- Advice to the business on regulatory requirements and change
- The relationship with the regulator, including notifications and supervisory contact
- Consumer Duty oversight, where allocated, and the annual board report
- Leadership of the compliance team, if there is one
MLRO (SMF17)
- Oversight of anti-money laundering systems and controls, under SYSC 6.3
- Acting as nominated officer under the Money Laundering Regulations, receiving internal reports and deciding whether to report to the National Crime Agency
- The firm’s business-wide risk assessment and policies
- The annual MLRO report to the board
- Sanctions screening and politically exposed persons, where allocated
- Financial crime training across the firm
Our guides to the MLRO role and SMF16 and SMF17 give more detail. If one person will do both roles, the job description should say so, and make clear how the time will be split.
Scenario: A growing e-money firm advertises for a “Compliance Manager” with a generic list of duties. Responses are mostly from mid-level candidates who don’t have the experience to hold SMF16 and SMF17. The firm rewrites the job description to name both functions, describe the safeguarding and financial crime risks of its business model, state that the role reports to the CEO with direct access to the board, and give a realistic salary range. The second round produces a shortlist of four approvable candidates within three weeks.
Mistakes That Cost Firms Good Candidates
| Mistake | Why it matters | Better approach |
|---|---|---|
| Not naming the SMF | Experienced candidates search by function; a vague title attracts the wrong level | Name the function and say approval is required |
| Generic duties copied from another firm | Candidates can’t tell whether their experience fits | Describe the firm’s actual activities and risks |
| Job description and SoR inconsistent | Creates confusion at interview and questions from the regulator | Draft the SoR first and align the two |
| Unrealistic experience list | Deters strong candidates who don’t tick every box | Separate essential from desirable |
| No salary information | Senior candidates often ignore roles without a range | Give a range based on current data; see our salary guide |
| Hiding the reporting line | Independence matters to control function candidates | State who the role reports to and its board access |
| Overloading the role | One person can’t credibly hold too many responsibilities; see combining SMF roles | Be realistic about scope and resources |
Using the Job Description Through the Process
A good job description keeps working after the advert closes. The hiring panel should use it to structure interview questions, so every candidate is assessed against the same accountabilities. Our guide to interviewing an SMF candidate shows how. The firm’s fitness and propriety assessment should test the candidate against it, using a tool such as our fit and proper assessment template. After appointment, it becomes the baseline for performance objectives and the annual assessment.
It also helps with the regulator. If the regulator asks how the firm satisfied itself that the candidate is competent for the role, a clear job description, aligned with the SoR and used throughout the process, is good evidence.
Advertising the Role
For SMF roles, the advert is often a shortened version of the job description, but the same principles apply. Name the function, give a salary range, describe the firm honestly and say how flexible the role is. Many firms prefer to advertise confidentially, particularly when replacing someone who hasn’t yet left. A specialist recruiter can run a confidential search and approach candidates who aren’t actively looking, which is often where the best Senior Managers are. You can see how we present roles on our current jobs page.
Checklist Before You Publish
- The Senior Manager Function is named and approval is mentioned
- The job description is consistent with the draft Statement of Responsibilities and responsibilities map
- The firm’s activities, size and risks are described accurately
- Reporting lines and board access are clear
- Essential and desirable experience are separated
- A salary range and working pattern are included
- The process, including the regulatory approval step, is explained
- Someone with SMCR knowledge has reviewed it
SMF Recruitment
From role design to approval. Every SMF search is led personally by Adrian Lawrence FCA
Control Functions
Compliance and financial crime roles.
→ Compliance officer (SMF16)
→ MLRO (SMF17)
Free Templates
Documents to support the hire.
→ SoR template
→ Responsibilities map template
Every SMF search is led personally by Adrian Lawrence FCA
Frequently Asked Questions
Is a job description the same as a Statement of Responsibilities?
No. The SoR is a regulatory document setting out what the Senior Manager is accountable for. The job description is an employment document. They must be consistent, and it helps to draft the SoR first.
Should the job description name the SMF?
Yes. Naming the function attracts candidates with the right experience and makes clear the role requires regulatory approval.
What should an MLRO job description include?
Oversight of anti-money laundering systems and controls, the nominated officer role, the business-wide risk assessment, the annual MLRO report, training and any sanctions or PEP responsibilities allocated to the role.
Should we include a salary range?
Yes. Senior candidates often ignore roles without one, and a realistic range saves time on both sides.
Can one job description cover SMF16 and SMF17?
Yes, if one person will hold both functions. Make clear how the role is split and that the firm has considered whether one person can do both effectively.
Can you help write our job description?
Yes. We help firms design the role, align the job description with the SoR and set a competitive package before the search begins.
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. He leads every SMF Capital search personally, starting with the role design and job description. 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.
