Interviewing a Head of Compliance or Chief Compliance Officer

What You Are Really Testing

Most firms interview compliance leaders on technical knowledge, and most shortlisted candidates pass that test easily. The things that decide whether a CCO succeeds are harder to see: judgement under pressure, the confidence to challenge senior colleagues, the ability to explain regulatory risk to a board, and the leadership to build a team the business respects. Your process should be designed to test those, not just recall of the rules.

It also has to anticipate the regulator. If the role holds SMF16 Compliance Oversight, the FCA will assess the candidate against the fit and proper test when you submit the Form A, and may interview them. The questions you ask, and the evidence you keep, are part of your own fit and proper assessment. Our guide to chief compliance officer and head of compliance recruitment explains how the job titles map to SMF16, and what is SMF16? covers the function itself.

A Four-Stage Interview Process

1. Experience interview. With the chief executive or the hiring director. Walk through the candidate’s career in detail: the firms, permissions, team sizes, reporting lines and the hardest regulatory issues they have handled.
2. Technical and scenario interview. With someone who can test depth, ideally an experienced compliance professional, a non-executive with a regulatory background or your outgoing SMF16. Use scenarios based on your own business.
3. Board presentation. Ask the candidate to present to two or three board members. A short brief works well: “What would you look at in your first 90 days, and what would you report to us at the end of the first quarter?”
4. Meeting the business. An informal session with two or three business heads the CCO will advise. You learn how the candidate builds relationships, and the business gets a say in someone they will work with every day.

Keep a written record of each stage. It becomes the backbone of your fit and proper assessment, and our fit and proper assessment template gives you a structure for it.

Questions on Experience and Track Record

• Which permissions and products have you been responsible for, and which of ours are new to you?
• How big was the compliance function you led, who reported to you, and who did you report to?
• Have you been approved as SMF16 before? At which firms, and for how long?
• What is the most significant compliance failing you have found, and how did you find it?
• Tell us about a time the FCA wrote to the firm, visited or asked for information. What did you do, and what was the outcome?
• What has changed in the firms you have worked for because of you?

What good sounds like: specific firms, specific issues and specific outcomes. Strong candidates talk about what they decided and why, not what “the team” or “the business” did. Our guide to the experience that matters for your type of firm explains why sector depth matters so much for this role.

Questions on Judgement and Challenge

This is the most important part of the interview. A CCO who cannot say no, or who says no to everything, will fail in different ways.

• Tell us about a time you disagreed with the chief executive or the board on a regulatory risk. What happened, and how was it resolved?
• Have you ever stopped a product, a campaign or a client relationship? What was the commercial cost, and how did you handle the people who wanted it?
• Describe a time you were wrong about a regulatory call. How did you find out, and what did you change?
• When is it right to accept a risk the business wants to take, and how do you record that decision?
• What would make you escalate an issue to the board without the chief executive’s agreement?

What good sounds like: real examples where the candidate held a position, found a compliant way forward where one existed, and documented what they did. Our guide to compliance officer independence explains why the regulator looks for evidence of challenge, and the duty of responsibility explains why the candidate should care about recording it.

Questions on Running the Function

• How would you build our compliance monitoring plan, and what would you look at first?
• What would your board report contain, and how often would we get it?
• How do you decide whether a breach needs to be notified to the FCA under SUP 15?
• How do you track regulatory change and make sure it turns into action?
• What would you want in your statement of responsibilities, and what would you push back on?
• How would you work with our MLRO, risk function and internal audit?

What good sounds like: a risk-based approach tied to your business, a clear view of what the board needs (not a long list of activity), and an understanding that their own accountability depends on the evidence the function produces. Our guide to what the board should see from the monitoring plan is a useful benchmark for their answers.

Questions on Leadership and the Team

• How would you size and structure our compliance team over the next two years?
• Tell us about someone you developed who went on to a bigger role.
• How have you handled a member of the team who was not performing?
• What would you outsource, and what must stay in-house?
• How do you make compliance useful to the business rather than a blocker?

Answers to the first question tell you a lot. A candidate who immediately asks for a large team without understanding your risks may be expensive. One who says they can do it all alone at a growing retail firm may be underestimating the work. Our guide to sizing the compliance team sets out how firms usually grow the function, and what you can and can’t outsource explains where the limits are.

Questions on Current Regulation

A compliance leader whose knowledge stopped moving a few years ago will struggle in a supervisory meeting. Ask about the changes that matter to your firm:

• How has the Consumer Duty changed the way you monitor outcomes, and what goes into the annual board report?
• What do the 2026 changes to the Senior Managers and Certification Regime mean for us?
• What are the FCA’s current priorities for firms like ours, and how do you keep up with them?
• Which recent enforcement cases or Dear CEO letters would you want our board to read?

For context on the 2026 reforms, see our guide to what has changed for Senior Managers, and for the enforcement picture, FCA enforcement trends.

Warning Signs

After the Interviews: References and Approval

For an SMF16 appointment, you must obtain regulatory references covering the previous six years from the candidate’s past employers in regulated firms. Our guide to regulatory references explains what to request and what to do if something comes back. Alongside that, run background checks, including the criminal records check, and complete your fit and proper assessment before the Form A goes in.

Prepare the candidate for a possible FCA interview too. Our guide to preparing for an approval interview covers what to expect, and what goes wrong in Form A submissions sets out the common mistakes. Once they start, the first 90 days is a good guide to what a strong start looks like.

If the Role Is Combined With MLRO

If your head of compliance will also hold SMF17, add a financial crime stage to the process, with scenarios on suspicious activity reports, sanctions and the business-wide risk assessment. Our guides to interviewing a combined compliance officer and MLRO and MLRO interview questions cover that side in detail.

Frequently Asked Questions

How many interview stages should a head of compliance hire have?

Three or four is typical: an experience interview, a technical or scenario interview, a board presentation and an informal meeting with the business. More than that tends to lose good candidates without adding much.

Who should interview a chief compliance officer?

The chief executive, at least one board member, and someone who can test technical depth, such as a non-executive with a regulatory background or an experienced compliance professional.

Should we ask candidates to give a presentation?

Yes. A short presentation to board members on the first 90 days is one of the best ways to see how a candidate thinks and communicates with the people they will report to.

Does the FCA interview candidates for SMF16?

It can. The FCA decides case by case whether to interview, so prepare every SMF16 candidate for the possibility.

What references do we need for a head of compliance?

For an SMF16 appointment, regulatory references covering the previous six years from past employers in regulated firms, plus your usual employment and background checks.