Chief Compliance Officer and Head of Compliance Recruitment

CCO, Head of Compliance and SMF16: How the Titles Fit Together

The FCA does not regulate job titles. It regulates functions. The function that matters here is SMF16 Compliance Oversight, which applies to Core and Enhanced firms under the Senior Managers and Certification Regime. The person who holds it is responsible for the firm’s compliance function and must be approved by the FCA before they start.

Firms give that person different titles depending on their size and culture:

• Chief Compliance Officer (CCO) is common in larger firms, international groups, asset managers, fintechs and US-owned businesses, and usually signals an executive committee seat.
• Head of Compliance is the most common title in UK brokers, wealth managers, lenders and mid-sized firms.
• Compliance Director is used where the role sits on, or reports directly to, the board.
• Compliance Officer is typical in small firms where the SMF16 is one person with little or no team.

In most firms, whichever title you use, that person is your SMF16. In larger groups, there can be a head of compliance who leads a team beneath the SMF16 holder, or several heads of compliance across business lines. They are usually within the Certification Regime rather than holding an SMF themselves. We recruit for both, and we will help you decide which you need before the search starts. Our compliance officer (SMF16) recruitment page covers the regulatory function in detail, and our guide to SMF16 and SMF17 explains what the FCA expects of the holder.

What a Chief Compliance Officer Does

A CCO leads the compliance function the firm must maintain under SYSC 6.1. That function must operate independently and have the authority, resources, expertise and access to information it needs. In practice, the CCO or head of compliance will:

• set the compliance strategy and risk appetite with the board, and report on compliance risk at every board or committee meeting;
• build and lead the compliance team, including advisory, monitoring, regulatory change and, in many firms, financial crime;
• own the compliance monitoring programme and present results in a form the board can act on, as covered in what the board should see;
• lead the firm’s response to Consumer Duty, including the evidence behind the annual board report;
• manage the relationship with the FCA, including supervisory meetings, information requests, breach notifications under SUP 15 and, where relevant, skilled person reviews;
• approve or oversee financial promotions and new product launches; and
• advise the chief executive and executive committee on regulatory risk in strategy, acquisitions and new markets.

As a Senior Manager, the CCO carries a statement of responsibilities and is subject to the duty of responsibility. They also often hold prescribed responsibilities. Our guide to prescribed responsibilities and our statement of responsibilities template help you set these out clearly.

CCO and MLRO: One Person or Two?

At smaller firms, the head of compliance often also holds SMF17 as the money laundering reporting officer. That is permitted, and it can work well where financial crime risk is moderate and the person has real AML experience. At larger firms, or those with higher financial crime risk such as payments, crypto and wealth management, the two roles are usually split, and the MLRO may report to the CCO or directly to the board.

The choice shapes the search, because a combined candidate needs depth in both conduct compliance and financial crime. See our pages on:

• combined compliance officer and MLRO recruitment (SMF16/SMF17);
• when to split a combined SMF16/SMF17 role; and
• MLRO recruitment (SMF17), for a standalone MLRO alongside your CCO.

Permanent, Interim and Fractional CCO Hires

We recruit chief compliance officers and heads of compliance on three bases. Many firms use more than one, for example an interim while the permanent search runs.

If a CCO leaves without warning, the FCA’s rules in SUP 10C allow temporary cover without approval where the absence is temporary or reasonably unforeseen. Since 24 April 2026, the firm has 12 weeks to submit an application for the person covering, and they can stay in post until the FCA decides. The application still has to be in within 12 weeks, so the search and the Form A should begin at once. Our article can we appoint them yet? covers the timing.

Which Firms Hire a Chief Compliance Officer?

The profile of a strong CCO varies more by sector than by title. We recruit compliance leaders across:

• Payments, e-money and fintech, where the CCO often also leads financial crime and safeguarding. See payments and fintech recruitment.
• Investment management and wealth, with a focus on MiFID, client assets and suitability. See investment managers and wealth management.
• Insurance and broking, including distribution oversight and appointed representatives. See insurance and compliance officers for insurance brokers.
• Consumer credit and lending, where Consumer Duty, affordability and collections dominate. See consumer credit.
• Crypto and digital assets, where regulation is new and experienced candidates are scarce. See crypto-asset firms.
• Banks and building societies, where the CCO works within a dual-regulated PRA and FCA framework. See banks and building societies.
• Principals with appointed representatives. See principal firm and AR recruitment.

What to Look For in a CCO or Head of Compliance

Technical knowledge is the entry ticket, not the decider. The candidates who succeed as CCO usually combine:

• Relevant sector depth. They have led compliance in a firm with similar permissions, products and customers. Our guide to the experience that matters for your type of firm explains why this matters.
• Board presence. They can explain regulatory risk clearly to non-specialists and hold their position under pressure.
• Commercial judgement. They help the business find a compliant way to do things, rather than only saying no.
• Leadership. They have built or led a team and can recruit, develop and keep good compliance people.
• Regulator experience. They have handled supervisory visits, information requests and, ideally, a difficult issue with the FCA.
• A clean approval record. They have been approved as SMF16 before, or can show why they are ready for their first SMF role.

Interview Questions for a Chief Compliance Officer

• What would you look at in your first 30 days here, and what would you report to the board at the end of the first quarter?
• Tell us about a time you disagreed with the chief executive on a regulatory risk. How was it resolved?
• How would you size and structure our compliance team over the next two years?
• Talk us through the most serious breach you have managed and how you handled the FCA.
• How do you evidence reasonable steps as SMF16, and what would your statement of responsibilities say?
• How do you work with the MLRO, the risk function and internal audit?

Our guide to interviewing an SMF candidate covers the wider Senior Manager interview, and our compliance officer and MLRO job description template is a good starting point for the brief.

Pay, Approval and Timing

CCO and head of compliance packages vary widely with firm size, sector, team size and whether the role combines SMF16 and SMF17. Our analysis of what SMF roles actually pay sets out current ranges, and we will give you a realistic view for your firm at the brief.

Because the CCO is usually a Senior Manager, the timetable has two parts: the search, and FCA approval. The FCA has up to three months to decide on a complete application, and incomplete or weak applications take longer. We help you prepare the Form A, the statement of responsibilities and your fit and proper assessment, drawing on our fit and proper assessment template and our guide to what goes wrong in Form A submissions. You can check a candidate’s current and past approvals on the FCA Register.

How We Run a CCO Search

1. Brief. We agree the title, the reporting line, whether the role holds SMF16, SMF17 or both, the size of the team and what the board needs from the role in its first year.
2. Search. We approach compliance leaders with experience in your sector, most of whom are not actively looking, and test their regulatory record and leadership before they reach you.
3. Shortlist. You receive a short, assessed shortlist with a clear view on each candidate’s strengths, gaps and likely approval questions.
4. Approval and onboarding. We support the Form A and the handover from your current SMF16 or interim, and our article on the first 90 days sets out what a good start looks like.

Our specialist team runs each search, and Adrian Lawrence FCA oversees every SMF Capital mandate. If you are looking for a compliance role yourself, see our compliance officer jobs page.

Frequently Asked Questions

Is a chief compliance officer the same as SMF16?

Usually, yes. In most firms the CCO or head of compliance is the person approved for SMF16 Compliance Oversight. In larger groups, a head of compliance may lead a team under the SMF16 holder and fall within the Certification Regime instead.

What is the difference between a CCO and a head of compliance?

Mainly the title and seniority. CCO tends to be used in larger, international or fintech firms and signals an executive committee seat. Head of compliance is more common in UK mid-sized firms. The regulatory function behind both is usually SMF16.

Does our CCO need FCA approval?

If they will hold SMF16, yes. They must be approved before they take up the function, although the 12-week rule allows temporary cover for an unforeseen absence, provided an application is submitted within 12 weeks.

Can the CCO also be the MLRO?

Yes, and in smaller firms it is common. The person needs genuine financial crime experience and enough time for both. Larger or higher-risk firms usually split SMF16 and SMF17.

Can we hire a fractional or interim CCO?

Yes. We place interim CCOs for vacancies and remediation, and fractional compliance officers who hold SMF16 for one to three days a week.

How long does a CCO search take?

We aim to present a shortlist within days of the brief for interim and fractional roles, and within a few weeks for permanent roles. FCA approval follows, and the regulator has up to three months to decide on a complete application.