Knowledge Centre: Guides, Q&As and Templates for the Senior Managers Regime

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New to the regime, or working out what applies to your firm? These guides give you the framework.

• SMCR explained: what the Senior Managers and Certification Regime is, why it exists and how it works.
• SMF designations: a complete guide: every Senior Manager Function from SMF1 to SMF29, with links to each detailed guide.
• Which SMFs apply at which firm tier?: the functions and responsibilities for Limited Scope, Core and Enhanced firms.
• SMCR glossary: every key term, from Form A to tipping off, explained in plain English with links to the detailed guides.
• SMCR reforms: what the regulators are changing, and what stays the same for Senior Managers.

Core Reference Guides

The rules and processes behind every Senior Manager appointment.

Practical Q&As and New Guides

Direct answers to the questions firms ask most often when structuring and filling Senior Manager roles, plus guides for firms going through significant change.

In-Depth Regulatory Guides

Detailed guides to the rules, processes and roles that shape Senior Manager accountability, from financial crime and client assets to prudential requirements and enforcement.

Financial Crime and Compliance Operations

Practical guides for MLROs, compliance officers and operations leaders, starting with how compliance monitoring works: the financial crime rules they apply every day, and the operational and reporting obligations that sit alongside them.

Compliance Officer, MLRO and Financial Crime Team Guides

Practical guides to structuring and filling the compliance and financial crime roles: combining or splitting SMF16 and SMF17, what the roles cost, and the team firms build around the MLRO.

Free Templates

Downloadable Word templates for the documents the regime requires. Each has a guide page explaining how to complete it, and each is free with no sign-up.

Guides by Topic

Getting a Senior Manager Approved

• The fitness and proper test in full
• What goes wrong in Form A submissions
• Regulatory references: the six-year rule
• How long an SMF appointment takes
• SMF timing and eligibility questions
• Hiring your first Senior Manager
• Pre-offer checks for SMF candidates
• SMCR background checks
• Interviewing a combined compliance officer and MLRO
• Regulatory reference checklist
• PRA vs FCA: who approves what
• Preparing for an FCA or PRA approval interview
• SMF application refused or withdrawn
• Adding an executive to the board: a checklist

Responsibilities and Structure

• The Responsibilities Map explained
• Responsibilities Map template
• Writing a Statement of Responsibilities
• Statement of Responsibilities template
• Combining Senior Manager roles
• When to split a combined SMF16 and SMF17 role
• SMF3 or SMF18?
• Group SMF roles
• SMF approval for overseas firms and groups
• Prescribed Responsibilities explained
• SMF7 Group Entity Senior Manager

Changes, Leavers and Notifications

• The 12-week rule
• Notification forms B, C, D and E
• Your MLRO has resigned: a 30-day plan
• SMF succession planning
• Keeping the SMF team after an acquisition
• Staffing a section 166 remediation
• Senior Manager handover packs
• Section 166 skilled person reviews explained

Conduct, Fitness and Certification

• Conduct Rules explained
• Conduct Rules training guide
• SMCR training: what firms must provide
• The Certification Regime explained
• Fit and proper assessment template
• FCA prohibition orders
• The Duty of Responsibility and reasonable steps

Firm Status and Authorisation

• Which SMFs apply at which firm tier?
• SMCR reforms: what’s changed
• SMCR glossary
• Becoming an Enhanced firm
• Going directly authorised
• The authorisation journey
• Threshold conditions and Part 4A permission
• Who can be your MLRO or compliance officer?
• Fractional or full-time compliance officer?
• How many days does a fractional MLRO or compliance officer need?
• Fractional SMF agreements
• What a combined compliance officer and MLRO costs
• Compliance officer and MLRO for brokers and advice firms
• Appointed representatives explained
• Payment and e-money institution authorisation
• Compliance outsourcing: what you can and can’t outsource
• Operational resilience explained

Financial Crime, Client Assets and Prudential Rules

• What is an MLRO?
• SMF16 and SMF17 explained
• The annual MLRO report
• The compliance monitoring plan
• Compliance monitoring plan template
• Compliance officer and MLRO job description template
• Who checks the checker? Combined SMF16 and SMF17
• When the MD is also the compliance officer
• CASS explained
• ICARA and IFPR explained
• The Consumer Duty for Senior Managers
• Consumer Duty and the SMF framework
• Politically exposed persons (PEPs)
• The Money Laundering Regulations 2017
• Sanctions screening and compliance
• Suspicious activity reports and the nominated officer
• Customer due diligence and EDD
• The business-wide risk assessment
• Transaction monitoring
• The failure to prevent fraud offence
• Safeguarding for payments and e-money firms
• Financial promotions: the compliance officer’s role
• Compliance monitoring explained
• Vulnerable customers: what the FCA expects
• REP-CRIM: the annual financial crime report
• Do you need a deputy MLRO?
• Head of financial crime or MLRO?
• Hiring a sanctions lead
• Sizing a payments firm’s financial crime team
• Hiring a crypto MLRO
• FCA regulatory reporting explained

Boards and Non-Executives

• Non-executive directors at FCA-regulated firms
• Board skills matrix template
• The Consumer Duty board champion
• The whistleblowers’ champion
• NED time commitment and overboarding
• PRA collective suitability

Designation Guides

Detailed guides to individual Senior Manager Functions:

• SMF1 Chief Executive
• SMF2 Chief Finance
• SMF3 Executive Director
• SMF4 Chief Risk
• SMF5 Head of Internal Audit
• SMF6 Head of Key Business Area
• SMF7 Group Entity Senior Manager
• SMF8 Credit Union Senior Manager
• SMF9 Chair
• SMF10 and SMF11 Committee Chairs
• SMF12 Remuneration Committee Chair
• SMF13 Nomination Committee Chair
• SMF14 Senior Independent Director
• SMF16 and SMF17
• SMF17 MLRO explained
• SMF18 Other Overall Responsibility
• SMF19 Head of Third Country Branch
• SMF20 Chief Actuary
• SMF22 Other Local Responsibility
• SMF23 Chief Underwriting Officer
• SMF24 Chief Operations
• SMF27 Partner
• SMF29 Limited Scope Function

For every function in one table, with the firms each applies to, see the SMF designations guide.

Knowledge Centre or Insights?

The Knowledge Centre explains the rules and how to comply with them. Our Insights section analyses developments, enforcement and how Senior Manager appointments work in practice. Many readers use both: the Knowledge Centre for what the rules require, and Insights for what that means when you have to appoint someone. For the state of the hiring market, see our quarterly SMF recruitment market update, and for examples of recent appointments, our case studies.

A Note on Sources

Our guides are written from experience of Senior Manager searches and refer to the regulators’ own rules, including the FCA Handbook and the PRA Rulebook. Rules change, so check the current requirements for your firm, and take legal or regulatory advice on specific situations. If you spot something that needs updating, please let us know.

Frequently Asked Questions

Are the templates really free?

Yes. Download them from each template page, with no sign-up, and adapt them for use within your firm.

Is this legal or regulatory advice?

No. The Knowledge Centre provides general guidance. For advice on a specific situation, speak to your compliance team or a regulatory lawyer.

Where do I start if I need to appoint a Senior Manager?

Read which SMFs apply at your firm tier and SMF timing and eligibility, then tell us about your hire.

Where should I start as a new MLRO or compliance officer?

Read what an MLRO does, the SMF16 and SMF17 guide and the first 90 days. New compliance officers should also read our guide to compliance monitoring.

Where do I start on financial crime?

Begin with what an MLRO does and the Money Laundering Regulations 2017, then the business-wide risk assessment, customer due diligence, transaction monitoring and suspicious activity reports. The guides to PEPs and sanctions screening complete the picture.

Should we have one person as compliance officer and MLRO?

Often, at smaller firms. Read combined compliance officer and MLRO recruitment, then when to split the role as your firm grows.

Is there a glossary of SMCR terms?

Yes. Our SMCR glossary defines every key term and links to the guide that covers it in detail.

Can you add a guide on a specific topic?

Yes. Get in touch and tell us what you need.