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of Responsibilities that works, what happens at an approval interview, and what to do if an application is refused or withdrawn.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 17 articles
What a Combined Compliance Officer and MLRO Costs: Salary vs Fractional Day Rate
For smaller FCA-regulated firms, one of the main reasons to combine compliance oversight (SMF16) and money laundering reporting (SMF17) in one person is cost. One experienced…
Read more about What a Combined Compliance Officer and MLRO Costs: Salary vs Fractional Day Rate
Interviewing a Combined Compliance Officer and MLRO: Testing Both Sides
Hiring one person to hold both compliance oversight (SMF16) and money laundering reporting (SMF17) is common at smaller FCA-regulated firms. It is also the appointment where…
Read more about Interviewing a Combined Compliance Officer and MLRO: Testing Both Sides
When to Split a Combined SMF16 and SMF17 Role: The Warning Signs
For many smaller FCA-regulated firms, one experienced person holding both compliance oversight (SMF16) and money laundering reporting (SMF17) is the right structure. It is proportionate, it…
Read more about When to Split a Combined SMF16 and SMF17 Role: The Warning Signs
Adding an Executive to the Board of an FCA-Regulated Firm: A Checklist
Adding an executive to the board of an unregulated company is a board resolution and a Companies House filing. At an FCA-regulated firm, it is a…
Read more about Adding an Executive to the Board of an FCA-Regulated Firm: A Checklist
The Annual MLRO Report: What the Board Should Expect
Once a year, the MLRO puts their assessment of the firm's financial crime controls in front of the board. Done well, the annual MLRO report is…
Read more about The Annual MLRO Report: What the Board Should Expect
The Compliance Monitoring Plan: What the Board Should Expect From Its SMF16
The compliance monitoring plan is where a compliance function shows whether it is actually working. It sets out what the compliance team will test, when, how…
Read more about The Compliance Monitoring Plan: What the Board Should Expect From Its SMF16
PRA Collective Suitability: What It Means for Board Appointments at Banks and Insurers
At banks, building societies and insurers, the regulators don't just assess whether each board candidate is suitable. The Prudential Regulation Authority also asks whether the board…
Read more about PRA Collective Suitability: What It Means for Board Appointments at Banks and Insurers
NED Time Commitment and Overboarding at Regulated Firms: How Much Is Too Much?
Experienced non-executives are in demand, and many build portfolios of several board roles. At unregulated companies that can work well. At regulated firms, it's more complicated:…
Read more about NED Time Commitment and Overboarding at Regulated Firms: How Much Is Too Much?The Whistleblowers’ Champion: Who Should Hold the Role, and Why It Matters
At banks, building societies and larger insurers, the regulators require a whistleblowers' champion: a named individual responsible for overseeing the firm's whistleblowing arrangements. Many other firms…
Read more about The Whistleblowers’ Champion: Who Should Hold the Role, and Why It MattersThe Consumer Duty Board Champion
When the FCA introduced the Consumer Duty, it asked firms to appoint, where appropriate, a board-level champion to help make sure the Duty is discussed regularly…
Read more about The Consumer Duty Board ChampionSMF Succession Planning: A Template for Boards
Most boards have a succession plan. Far fewer have one that would work on the day a Senior Manager leaves. The reason is simple: in a…
Read more about SMF Succession Planning: A Template for Boards
Your MLRO Has Resigned: A 30-Day Plan
When a Money Laundering Reporting Officer hands in their notice, the clock starts on several things at once. The firm must never be without a nominated…
Read more about Your MLRO Has Resigned: A 30-Day PlanBrowse 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.