The SMF Recruitment Blog
Practical guidance on hiring, approving and supporting Senior Managers at FCA and PRA-regulated firms, written for chief executives, chairs, nominations committees, HR directors and compliance leads.
How the SMF Capital Blog Works
Every article answers a question we are asked on live searches. Hiring a Senior Manager is not like hiring any other executive. The person cannot start in the function until the regulator approves them, the firm has to show the regulator that it has assessed them as fit and proper, and once they are in post they carry personal accountability for the areas set out in their Statement of Responsibilities. Getting any of that wrong costs months.
So the blog stays practical. It explains what the Senior Manager Functions mean in practice, what the regulator looks for at approval, what good candidates look like for each role, what they cost, and how long the process really takes. Where the rules matter we link to the source, in particular the FCA’s guidance on the Senior Managers and Certification Regime and, for banks and insurers, the Prudential Regulation Authority.
New to the subject? Start with one of the core guides on the right, or use the search and topic filters above to find what you need.
Start here
SMF designations: a complete guide →Every Senior Manager Function and which firms need it. Senior Manager Functions explained →How the regime works, from approval to the duty of responsibility. SMF and compliance salary guide →Salaries and day rates for Senior Manager and compliance roles. The 12-week rule →Covering an unexpected Senior Manager vacancy while you recruit.Approval and Designations
Which SMF a role needs, how to write a Statement of Responsibilities that works, what happens at an approval interview, and what to do if an application is refused or withdrawn.
Compliance and Financial Crime
Hiring and supporting your SMF16 Compliance Oversight and SMF17 MLRO: interview questions, the annual MLRO report, compliance monitoring plans and how to cover a sudden vacancy.
Boards, Pay and Offers
Chairs, committee chairs and NEDs, collective suitability, time commitment, what SMF roles actually pay, and how to structure an offer that survives the wait for approval.
Latest Articles on Senior Manager Hiring
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Showing 1–12 of 74 articles
When a Section 166 Review Forces a Change of SMF16 or SMF17
A skilled person review under section 166 of FSMA is one of the FCA's most significant supervisory tools, and when the review looks at compliance or…
Read more about When a Section 166 Review Forces a Change of SMF16 or SMF17
MLRO for Payments and E-Money Firms: The Experience the FCA Looks For
At a payments or e-money firm, the MLRO is one of the first people the FCA assesses at authorisation and one of the first it calls…
Read more about MLRO for Payments and E-Money Firms: The Experience the FCA Looks For
What the FCA Expects From a First-Time SMF16 at a Newly Authorised Firm
Newly authorised firms often appoint a compliance officer who is taking on SMF16 for the first time, sometimes in the same month the firm starts trading.…
Read more about What the FCA Expects From a First-Time SMF16 at a Newly Authorised Firm
FCA Compliance Consultant or Approved SMF16: How to Choose for a Small Firm
Small FCA-regulated firms often start by searching for an "FCA compliance consultant", when what the regulator actually requires is an approved Senior Manager accountable for compliance.…
Read more about FCA Compliance Consultant or Approved SMF16: How to Choose for a Small Firm
Compliance Officer for Fintech and Payments Firms: The Experience That Survives FCA Scrutiny
Fintech and payments firms are among the most closely supervised businesses the FCA regulates, and the compliance leader is usually the first person the regulator wants…
Read more about Compliance Officer for Fintech and Payments Firms: The Experience That Survives FCA ScrutinyCompliance Officer for Consumer Credit Firms: When You Need an SMF16 and the Profile That Works
Consumer credit is one of the most closely watched parts of the FCA's remit, and the compliance officer's job is shaped by affordability, arrears, vulnerable customers…
Read more about Compliance Officer for Consumer Credit Firms: When You Need an SMF16 and the Profile That WorksCan One Person Hold SMF16 at More Than One Firm?
Yes. There is no rule that stops an experienced compliance officer holding SMF16 at two, three or four unrelated firms at once, and most fractional compliance…
Read more about Can One Person Hold SMF16 at More Than One Firm?How to Check Who Holds an SMF on the FCA Register
The Financial Services Register is the quickest way to see who a firm's Senior Managers are, when they were approved and what else they have done…
Read more about How to Check Who Holds an SMF on the FCA RegisterCASS 8 Mandates Explained for Smaller Firms
Many small firms that never hold client money still fall within the client assets rules, because they hold something that lets them move a client's money…
Read more about CASS 8 Mandates Explained for Smaller Firms
Compliance Monitoring for Investment Firms: What to Test and How Often
A compliance monitoring plan for a discretionary manager, wealth manager or advice firm should look very different from one for a payments firm or a broker.…
Read more about Compliance Monitoring for Investment Firms: What to Test and How Often
Reducing Sanctions Screening False Positives at a Wealth Manager
A wealth manager with 15,000 clients can easily find its sanctions screening queue full of alerts that are almost never real matches. Analysts clear the same…
Read more about Reducing Sanctions Screening False Positives at a Wealth Manager
CASS Resolution Pack: What It Must Contain and Who Owns It
If a firm holding client money or custody assets fails, the insolvency practitioner's first question is where everything is. The CASS resolution pack exists to answer…
Read more about CASS Resolution Pack: What It Must Contain and Who Owns ItBrowse the Blog by Topic
Four themes cover most of what firms ask us when they are hiring a Senior Manager. Every SMF search is overseen by Adrian Lawrence FCA.
Approval & Designations
Getting the designation, the Statement of Responsibilities and the approval process right before you recruit.
→ Preparing for an FCA or PRA approval interview→ When an SMF application is refused or withdrawn→ SMF3 or SMF18? Getting the designation right→ Statements of Responsibilities that work→ Group SMF roles and approval→ Managing the gap between offer and startSMF designations guide →
Compliance & Financial Crime
Hiring, onboarding and supporting your SMF16 and SMF17, and what to do when one leaves.
→ Hiring a compliance officer for your type of firm→ The compliance monitoring plan→ MLRO interview questions→ The annual MLRO report→ Your MLRO has resigned: a 30-day plan→ Does a general insurance broker need an MLRO?MLRO recruitment →
Boards & Governance
Chairs, committee chairs, NEDs and the board-level roles the regime puts under the spotlight.
→ Adding an executive to the board: a checklist→ PRA collective suitability→ NED time commitment and overboarding→ The Consumer Duty board champion→ The chair–CEO chemistry problem→ SMF succession planning for boardsChair and committee chair recruitment →
Hiring, Pay & Offers
What Senior Managers cost, how long the search takes and how to land the candidate you want.
→ What SMF roles actually pay→ How long an SMF appointment takes→ Buy-outs, notice periods and clawback→ Pre-offer checks for SMF candidates→ Fractional SMF agreements→ How many days a fractional MLRO needsFractional and interim SMF cover →
Every SMF search is overseen by Adrian Lawrence FCA
Go Deeper With Our Guides
Structured guides that bring the best material together by subject. See the full Knowledge Centre for every guide, template and explainer.
Knowledge Centre
Explainers on the SMCR, approval and accountability.
The Certification Regime →The duty of responsibility →Open the Knowledge Centre →Free Templates
Documents boards and compliance teams use most.
Statement of Responsibilities →Compliance monitoring plan →All free guides →Insurance Brokers
Compliance, client money and going directly authorised.
Compliance officer for brokers →CASS 5 client money →Becoming a DA broker →Pay and Timing
What Senior Managers cost and how long hiring takes.
Salary guide →What goes wrong in Form A →Urgent SMF replacement →Senior Manager Recruitment, Written From Experience
SMF Capital recruits Senior Manager Function holders for UK regulated firms: executive and non-executive, permanent, interim and fractional. We work with wealth and investment managers, consumer credit lenders, insurers and intermediaries, banks and building societies, payments, e-money and fintech firms, crypto-asset firms and overseas firms opening UK branches.
Senior Manager hiring sits where recruitment, regulation and governance meet, and most general recruiters only see one part of it. Our background is in finance leadership and regulated businesses, which is why the blog treats the regulatory side as part of the hiring decision rather than an afterthought.
The articles here come out of that work. When a client asks how long an approval will take, whether a candidate’s experience will satisfy the regulator, or how to cover an MLRO who has just resigned, the answer usually ends up as a blog post. You can check any individual’s approval history yourself on the FCA Financial Services Register, and our guide to the fit and proper test explains what the regulator assesses.
Listen to SMF Unlocked
Our podcast on Senior Manager hiring, approval and accountability, with short episodes on the questions firms bring to us.
Listen on Apple PodcastsFive Questions Every Firm Should Answer Before Recruiting a Senior Manager
Most of the problems we see on Senior Manager searches start before the first candidate is approached. These are the five questions that save the most time, and the articles that go into each one in more depth.
- Which designation does the role need? The function decides who can do the job and what the regulator will test. A role that sits between SMF3 and SMF18, or between SMF16 and a combined SMF16/17, needs settling first. Start with SMF3 or SMF18 and our designations guide.
- What will the Statement of Responsibilities say? The candidate will be accountable for exactly what is written down, so strong candidates read it closely. Our article on writing a Statement of Responsibilities and the free template help.
- How long can the firm wait? Approval can take up to three months after a complete application is submitted, on top of the search and any notice period. See how long an SMF appointment really takes and plan interim cover if the gap is too long.
- What will the role cost? Senior Managers are paid for the personal accountability they take on, not just the job title. Our salary guide and what SMF roles pay set out current day rates and salaries.
- Full-time, part-time or fractional? Smaller firms often need an experienced Senior Manager for two or three days a week rather than a full-time hire. Read fractional or full-time compliance officer before you decide.
Frequently Asked Questions
Who writes the SMF Capital blog?
Adrian Lawrence FCA and the SMF Capital team. Every article is based on questions raised on live Senior Manager searches, and each one is reviewed by Adrian before it is published.
How often are new articles published?
We publish new articles most weeks and update existing guides when the rules or the market change, so the salary and timing figures stay current.
Can you write about a topic we are dealing with?
Yes. If your firm is working through a Senior Manager question that is not covered here, get in touch. If it is a common problem we will usually write it up, without naming you.
Do you recruit for the roles you write about?
Yes. We recruit every Senior Manager Function, from the SMF16 compliance officer and SMF17 MLRO to chairs, chief executives and SMF2 chief finance officers, on a permanent, interim or fractional basis.
Is the blog useful for candidates as well as firms?
Yes. Articles such as due diligence before accepting an SMF role and preparing for an approval interview are written for Senior Managers. If you are considering your next role, register as a candidate; every conversation is confidential.
Do you only cover FCA-regulated firms?
We cover both FCA solo-regulated firms and dual-regulated banks, building societies and insurers, where the PRA also approves Senior Managers. Articles such as dual-regulated SMF hiring explain how the two regulators divide the work.
About Our Founder
SMF Capital was founded by Adrian Lawrence FCA, a Fellow of the Institute of Chartered Accountants in England and Wales who holds an ICAEW practising certificate in his own name (Chartered Accountant). He is a former listed-company Finance Director with a BSc from Queen Mary College, University of London, and more than 25 years of experience working with boards, investors and owner-managers.
Adrian founded FD Capital in 2018 and built FD Capital Group, five specialist recruitment firms including Exec Capital, NED Capital and Accountancy Capital. He set up SMF Capital so that FCA and PRA-regulated firms could hire Senior Managers with the regulator’s fit and proper assessment built into the search from the first conversation. He oversees every SMF search, working with an experienced senior team.
We work in line with the UK government’s Standard Voluntary Code of Conduct for Executive Search Firms. SMF Capital is a trading name of FD Capital Recruitment Ltd.