Start From the Statement of Responsibilities

The best Senior Manager interviews are built around the draft Statement of Responsibilities the candidate will sign. It tells the interview panel exactly what the candidate will be accountable for, and it gives structure to the questions. If the Statement isn’t drafted yet, draft it before the interviews. Our article on writing a Statement of Responsibilities explains how.

From there, a strong interview covers five areas: the candidate’s understanding of the regime, their experience against each responsibility, their judgement under pressure, their approach to challenge and escalation, and their fitness and propriety.

1. Understanding of the Regime

Candidates for Senior Manager roles should understand the regime they’ll be operating under, including the Senior Manager Conduct Rules and the Duty of Responsibility.

• “What does the Duty of Responsibility mean for you personally in this role?”
• “What would ‘reasonable steps’ look like in your area during your first six months?”
• “How do the Senior Manager Conduct Rules affect the way you’d delegate?”

Strong answers connect the rules to specific actions: the management information they’d want, the controls they’d test, how they’d document decisions. Weak answers recite definitions without saying what the candidate would actually do.

2. Experience Against Each Responsibility

Take each significant responsibility in the draft Statement and ask the candidate for evidence they’ve done that work before.

• “Tell us about a time you were responsible for [specific area]. What did you change, and how did you know it worked?”
• “Which of these responsibilities have you not covered before, and how would you close that gap?”
• “What would you want to know about this area in your first week?”

For first-time Senior Managers, this is where the case for approval is built. A deputy MLRO who has run suspicious activity reporting and presented the annual MLRO report has real evidence for an SMF17 role, even without having held the function. Candidates who are honest about gaps and have a plan to close them are usually a better bet than those who claim to have covered everything.

3. Judgement Under Pressure

Scenario questions based on the firm’s real risks show how a candidate thinks. Keep them specific to the role and the firm.

• “A complaint trend suggests one of our products isn’t delivering fair value, but it’s our most profitable line. What do you do?”
• “You discover a significant breach in your area that happened before you joined. What are your first three steps?”
• “The chief executive wants to launch a new product next month. You’re not comfortable it’s ready. How do you handle it?”

Strong answers balance commercial reality with regulatory obligations, escalate appropriately and consider whether the regulator needs to be told. Weak answers either defer entirely to the business or treat every issue as a reason to stop.

4. Challenge and Escalation

Senior Managers, particularly in control functions, need the confidence to challenge colleagues and the board. The regulator looks for evidence of this, and so should the firm.

• “Tell us about a time you disagreed with a senior colleague or the board on a regulatory issue. What happened?”
• “When would you go directly to the chair or an independent non-executive rather than through the chief executive?”
• “How would you handle a situation where you believed the firm should notify the FCA and others disagreed?”

Candidates who’ve never challenged anyone, or who describe challenge only in abstract terms, may struggle in roles where independence is essential, such as SMF4 Chief Risk or compliance oversight.

5. Fitness and Propriety

Every candidate will be assessed against the fit and proper test. Asking directly at interview avoids surprises later.

• “Is there anything in your regulatory history, references, directorships or finances we should know about before we go further?”
• “Have you ever been subject to disciplinary action, a regulatory investigation or a dispute with a former employer?”
• “What other roles or commitments do you currently have?”

Ask these questions neutrally and explain why you’re asking. Most candidates will be open. An issue raised at interview can usually be assessed fairly. One discovered in a regulatory reference after an offer is much harder to manage. Our article on checking a Senior Manager candidate before you make an offer covers the checks to run alongside the interview.

Adapting the Interview for Fractional and Interim Candidates

Fractional and interim Senior Managers need the same assessment as permanent appointments, with a few extra questions. The firm needs to know how the arrangement will work in practice, and the regulator will ask the same thing.

• “How many days a month will you commit to us, and what happens when something urgent arises on a day you’re not working for us?”
• “What other Senior Manager roles do you hold, and how do you manage conflicts between them?”
• “How will you stay close enough to the business to know what’s really happening?”

Strong candidates will have clear, practical answers from experience. Candidates holding many roles should be able to show that each firm gets the attention its risks require.

Preparing Candidates for a Regulator Interview

The regulator may interview candidates for Senior Manager roles, particularly at larger or higher-risk firms and for first-time applicants. The firm’s own interview is good preparation. Candidates who’ve already answered detailed questions about their Statement of Responsibilities, the firm’s risks and their approach to the role tend to perform well with the regulator too.

Before a regulator interview, it helps to make sure the candidate has read the firm’s business plan, risk appetite, recent board papers and any correspondence with the regulator relevant to their area, and can talk about specific risks rather than general principles.

Who Should Be on the Panel

For most Senior Manager appointments, the panel should include the person the candidate will report to and at least one person who can test their regulatory knowledge independently, often the chair, an independent non-executive or a senior compliance or risk leader. For control function roles, independence matters: the panel shouldn’t consist only of people the candidate will be expected to challenge.

For board and C-suite appointments at larger regulated firms, our sister practice Exec Capital runs FCA-regulated executive search, with structured interviews built around the same principles.

A Simple Interview Framework

• Before: draft the Statement of Responsibilities and agree which responsibilities matter most.
• First interview: experience against each responsibility, and fitness and propriety.
• Second interview: scenarios based on the firm’s real risks, and challenge and escalation.
• Final stage: meeting the chair or board, and discussion of what the candidate will inherit.
• After: record why the firm considers the candidate fit and proper, ready for the application.

The Bottom Line

A Senior Manager interview should test whether the candidate is ready for accountability, not just whether they’re good at the job. Building the interview around the Statement of Responsibilities, using realistic scenarios and asking about fitness and propriety directly gives the firm a far better basis for its decision, and a far stronger application. Every SMF Capital search includes this assessment before a candidate reaches your shortlist; our SMF recruitment services page explains how.