Why Combined Roles Need a Different Interview

A standard Senior Manager interview tests experience, judgement and fit. For a combined role, it has to do that twice, because the regulator will assess the candidate against both functions when it considers the application. The FCA’s fit and proper standards require competence and capability for each function the person will hold, not an average across the two.

The practical problem is that compliance and financial crime use overlapping language. A candidate can talk fluently about risk assessments, policies, monitoring and board reporting without revealing whether they have actually owned a compliance monitoring plan or made a difficult suspicious activity decision. Generic questions get generic answers. Specific questions, scenarios and work samples get evidence.

Before the interview, be clear about what the role involves. Our page on combined compliance officer and MLRO recruitment covers when the structure works and the profile firms look for.

Structure the Interview in Three Parts

The most reliable approach is to split the interview into three distinct parts, ideally with different interviewers leading each:

Score each part separately. A candidate who scores very well on one function and poorly on the other is not a strong combined candidate, however impressive the total.

Part One: Testing the Compliance Side

Good compliance questions ask the candidate to describe what they did, not what should be done. Examples:

• Walk us through the last compliance monitoring plan you owned. How did you decide what to test, and what did you find?
• Tell us about a monitoring finding that the business disagreed with. How did you handle it, and what was the outcome?
• How did you evidence good customer outcomes to the board under the Consumer Duty? What data did you use?
• Describe a financial promotion you refused to approve. What was wrong with it, and how did the conversation with the business go?
• What were the main complaint themes in your last role, and what did you change as a result?
• How did you implement the last significant piece of regulatory change at your firm?

Strong answers are specific: they name the test, the finding, the disagreement and the result. Weak answers describe frameworks and policies without examples. Our guide to the compliance monitoring plan sets out what a good plan looks like, which helps interviewers judge the answers.

Part Two: Testing the Financial Crime Side

Financial crime questions should focus on judgement and decisions, because that is what the MLRO role turns on. Examples:

• Talk us through the business-wide risk assessment at your last firm. What were the highest risks, and how did they shape your controls?
• Describe an internal suspicion report where you decided not to submit a SAR. How did you reach that decision and record it?
• Describe one where you did submit. What made the difference?
• How did you handle a request from the business to onboard a higher-risk customer quickly?
• What did your transaction monitoring rules actually look for, and when did you last tune them?
• How have sanctions changed your work since 2022?
• What did you include in your last annual MLRO report to the board?

Listen for evidence of real decisions, an understanding of the legal duties around reporting and tipping off, and familiarity with the typologies relevant to your sector. Our guide to MLRO interview questions goes deeper on this part, and the JMLSG guidance is a useful reference for interviewers.

Part Three: Testing the Combination

The third part is the one most firms leave out, and it’s the one that predicts whether the combined role will work in practice. Questions should test how the candidate will manage two functions with limited time:

• If you had two days a week, how would you split your time between compliance and financial crime?
• What would you delegate or outsource, and what would you keep?
• Which side would you expect to take more of your time here, and why?
• How would you make sure the board gets an equally clear picture of both functions?
• Who would cover urgent suspicious activity decisions on your days off?
• When would you tell us the role had become too big for one person?

The last question is particularly revealing. A strong candidate will describe specific warning signs and say they would raise them. A weaker one will say it won’t happen. Our guide to when to split a combined SMF16 and SMF17 role sets out the signs a good candidate should recognise.

Use a Practical Exercise

Interviews test what candidates say. A short practical exercise tests what they do. For a combined role, a two-part exercise works well:

• A conduct exercise. Give the candidate a draft financial promotion, a complaint file or a summary of monitoring results, and ask what they would raise and with whom.
• A financial crime exercise. Give them an anonymised internal suspicion report with some customer and transaction history, and ask whether they would submit a SAR and how they would record the decision.
• A short board note. Ask them to summarise both exercises in a one-page note for the board.

Ninety minutes is usually enough. The board note is often the most useful part, because it shows whether the candidate can explain both functions clearly and in balance to a non-specialist audience.

Red Flags to Watch For

None of these automatically rules a candidate out, but each deserves a follow-up question.

Checks Before the Offer

For any Senior Manager, the firm must be satisfied the candidate is fit and proper before applying for approval. For a combined role, those checks should cover both functions:

• previous approvals, including for SMF16, SMF17 or the legacy controlled functions;
• regulatory references covering the past six years, as our guide to the six-year rule explains;
• evidence of formal deputising where the candidate hasn’t held the title;
• any past regulatory involvement, discussed early and in confidence; and
• the candidate’s other commitments if the role is fractional.

Our guide to pre-offer checks for SMF candidates covers the full list. Draft the Statement of Responsibilities at the same time, setting out each function separately. It is needed for the application and it helps both sides confirm what the role involves.

How We Help

When we run a combined search, we test both sides before a candidate reaches the client: we interview for each function separately and check the evidence behind each claim. Our shortlists say clearly where each candidate is strongest and where they would need support. If a firm’s risks point towards separate appointments, we say so, and we can recruit a dedicated compliance officer or MLRO instead.

Frequently Asked Questions

Should one interviewer cover both functions?

It’s better not to. Different interviewers for each function reduce the risk that a strong performance on one side colours the assessment of the other.

Is a practical exercise reasonable for a senior candidate?

Yes, if it’s short and relevant. Most experienced compliance professionals welcome the chance to show how they work, and the exercise often decides close contests.

What if no candidate is strong on both sides?

Consider appointing the candidate who is strongest on your firm’s higher-risk side and adding support on the other, or separating the roles.

Does the FCA interview combined candidates?

The regulator may interview candidates for Senior Manager roles, particularly at larger firms or where it has questions. If it does, it will cover both functions.