About SMF Capital

SMF Capital is a specialist recruitment practice built around one specific problem: FCA Senior Manager Function appointments carry personal, evidenced regulatory accountability, and most recruitment processes are not built to test for that accountability properly. We exist to close that gap — for executive designations like Compliance Oversight and the Chief Risk Officer function, and for the non-executive board designations like Chair and Senior Independent Director, wherever they sit within our wider group.

Why We Exist

Every Senior Manager Function under the FCA’s Senior Managers and Certification Regime attaches individual accountability to a named person — a Statement of Responsibilities specifying exactly what they answer for, and a Duty of Responsibility that can see the FCA, or the PRA at dual-regulated firms, investigate that individual personally if governance or conduct failures occur within their area and they can’t show they took reasonable steps to prevent them. That is a fundamentally different standard from an ordinary senior hire, and it changes what a recruitment process actually needs to test for.

In practice, we found this gap by running into it repeatedly across our other practices. A Finance Director search that turned out to be an SMF2 search. A non-executive search that turned out to be an SMF9 or SMF14 search. A compliance hire where the individual would be taking on personal criminal liability under the Proceeds of Crime Act as the firm’s MLRO, and the brief hadn’t mentioned it. Each time, the fitness and propriety assessment that the FCA would eventually require was treated as a formality to handle once a hiring decision had effectively already been made, rather than a test that should shape who reaches the shortlist in the first place. SMF Capital was built to fix that — to make the regulatory accountability the starting point of the search, not an afterthought at the end of it.

What We Do

We work across the full range of SMF designations, both executive and non-executive. On the executive side, that includes the Chief Executive function, the Chief Risk Officer, Head of Internal Audit, Compliance Oversight and the Money Laundering Reporting Officer, along with less commonly discussed designations such as Other Overall Responsibility and the Partner function used at regulated partnerships and LLPs. On the non-executive side, that includes the Chair of the Governing Body, the Senior Independent Director, and the committee chair designations — Risk, Audit and Remuneration — that sit at board level.

We also work with the finance and compliance teams that sit underneath an SMF holder and, in practice, determine whether that individual can genuinely stand behind what they’re personally accountable for — client money and CASS specialists, Financial Controllers at FCA-regulated firms, and the regulatory reporting function that produces the returns a Compliance Oversight or MLRO holder signs off. An SMF appointment is only as strong as the team supporting it, and we think searches should reflect that rather than treating the individual designation in isolation.

How We Work

The fit and proper test shapes the search, not the paperwork at the end

Every SMF appointment requires a Form A submission to the FCA, assessed against three things: honesty, integrity and reputation; competence and capability; and financial soundness. That assessment has to be evidenced, not asserted. We build it into the search itself — testing candidates against exactly what the regulator will ask about before they ever reach a shortlist — because a search that does this consistently clears Form A faster and with fewer follow-up questions than one that treats regulatory approval as a final hurdle.

Designation-specific, not general seniority

We don’t treat “FCA-regulated firm experience” as a single, portable credential, because it isn’t one. An audit committee chair candidate needs financial experience that’s specifically relevant to the firm’s sector and reporting framework. A CASS specialist who’s worked under the CASS 7 investment firm regime doesn’t automatically understand the CASS 15 debt management regime. A strong SMF16 candidate for one sector’s regulatory complexity may be underprepared for another’s. We specify the exact regulatory context in every brief, and assess against it directly.

Realistic timelines, planned from the start

An SMF appointment has two phases — the search itself, and Form A approval, which runs afterwards and typically adds three to six months before the individual can start. We plan every search against the realistic total timeline from the outset, rather than letting boards discover the second phase only once an offer has already been made.

Founder-led, every time

Every search at SMF Capital, executive or non-executive, is led personally by Adrian Lawrence FCA — not handed to a junior consultant partway through. That matters more here than in most recruitment contexts, because assessing a candidate’s genuine readiness for personal regulatory accountability isn’t something that scales well through a large team; it requires the same person understanding the regulatory context, the firm’s specific situation, and the candidate’s actual fit against all three, consistently, from the first conversation through to the individual’s start date.

Part of a Wider Group

SMF Capital sits alongside four sister practices, each built around a different tier of senior appointment. Where a search calls for a specialism that sits more naturally with one of them — a CFO search that isn’t SMF-designated, a board search with no regulatory dimension, a finance appointment below director level — we say so directly and make the introduction, rather than trying to force every enquiry through SMF Capital regardless of fit.