SMF17 recruitment: finding the right mlro

Welcome to FD Capital. We recruit Money Laundering Reporting Officers (MLROs) and deputy MLROs for FCA-regulated businesses, providing permanent, fractional and interim recruitment.Our specialist recruitment service:https://www.fdcapital.co.uk/smf17-recruitment/What does an SMF17 MLRO do?SMF17 is the Senior Management Function responsible for the Money Laundering Reporting Officer role.The role also involves overseeing anti-money laundering systems, transaction monitoring, customer due diligence and financial crime controls.A strong MLRO must be able to make defensible decisions when the evidence is unclear. Filing every alert automatically is not good judgement, nor is allowing commercial pressures to override financial crime concerns.Permanent, fractional or interim recruitmentPermanent MLRO: Appropriate where transaction volumes, customer onboarding and financial crime risks create a continuous workload. Larger payments and e-money businesses often need a dedicated full-time appointment.Fractional MLRO: Suitable for smaller firms with limited AML activity. An experienced professional can provide senior oversight for an agreed number of days each month.Interim MLRO: Essential when an existing holder resigns, becomes unavailable or the business needs immediate support during a regulatory review or remediation programme.The volume of alerts and escalations is a particularly important consideration. A part-time arrangement that worked when a business was small may become inadequate as it grows.What makes a good MLRO?We look for candidates with practical experience, not simply impressive qualifications.Important qualities include:Previous SMF17 experience in a comparable business.Strong AML and financial crime knowledge.Experience assessing and submitting SARs.Understanding of the consent regime.Transaction monitoring expertise.Experience dealing with FCA supervision.Confidence challenging senior management.A sound fit and proper record.The ability to assess transaction monitoring systems is particularly valuable. An effective MLRO must recognise whether alerts identify genuine risks or simply generate unnecessary work.Why deputy MLROs matterFirms should not rely entirely on one individual. Holidays, illness and resignation can leave a serious gap in financial crime oversight.A properly briefed deputy MLRO should have appropriate system access and understand the firm's escalation procedures. They should be capable of supporting continuity when the principal MLRO is unavailable.FD Capital recruits deputy MLROs alongside senior SMF17 appointments.Which businesses need MLROs?We recruit across payments and e-money, cryptoasset businesses, consumer credit, wealth management, investment management and insurance distribution.The right candidate must understand the firm's particular risks. Experience in a small insurance intermediary does not automatically prepare someone for a high-volume international payments business.We assess sector knowledge, transaction volumes, customer profiles and regulatory exposure before defining the recruitment brief.FCA approval and accountabilitySMF17 is a pre-approval function. The individual cannot take up the approved responsibilities until the FCA has granted approval.The process includes a Form A through Connect, a Statement of Responsibilities and a fit and proper assessment.Firms should start recruitment promptly when an MLRO gives notice. An empty MLRO position is not simply an unfilled vacancy: it can leave the business without someone making essential SAR decisions.How FD Capital helpsWe establish the firm's risk profile, transaction volumes and requirements before approaching our specialist candidate network.We assess candidates for relevant experience, regulatory judgement, availability and capacity. For fractional and interim mandates, we generally aim to provide an initial shortlist within 72 hours.Every search is overseen by Adrian Lawrence FCA.Contact FD CapitalIf you need a permanent MLRO, fractional SMF17 holder, interim appointment or deputy MLRO, contact our team for a confidential discussion.Telephone: 020 3287 9501Email: [email protected]://www.fdcapital.co.uk/smf17-recruitment/FD Capital – specialist recruitment for FCA-regulated businesses.

Welcome to FD Capital. We specialise in recruiting SMF16 Compliance Oversight holders for FCA-regulated businesses, covering permanent, fractional, part-time and interim appointments.Finding the right SMF16 is not simply about recruiting someone with compliance qualifications. The individual must understand the firm's risks, challenge senior management and be capable of dealing confidently with the FCA.Our specialist recruitment service:https://www.fdcapital.co.uk/smf16-recruitment/What does an SMF16 do?SMF16 is the Senior Management Function responsible for Compliance Oversight under the Senior Managers and Certification Regime.The holder oversees the firm's compliance function and monitoring programme, reports regulatory risks to the board and helps ensure the business meets its FCA obligations.This is a position requiring sound judgement and independence. A strong candidate must be willing to challenge commercial decisions where necessary, not simply explain regulatory rules.Permanent, fractional or interim?Not every firm needs a full-time Head of Compliance.Permanent SMF16: Appropriate when the compliance workload requires daily involvement, a dedicated team and an established senior leader.Fractional SMF16: Often suitable for smaller firms where compliance work is substantial but intermittent. Two or three days a month may provide experienced oversight without the cost of a full-time appointment.Interim SMF16: Useful following a resignation, during parental leave, or when a firm needs additional expertise for remediation or regulatory change.The right structure depends on transaction volumes, product complexity, regulatory exposure and the firm's growth plans.What makes a strong candidate?We look for professionals who have held SMF16 at a comparable business, understand the relevant sector and have dealt directly with FCA supervision.Important qualities include:Strong compliance monitoring experience.Confidence reporting to boards and challenging directors.Practical knowledge of FCA requirements.Clear judgement and independence.Relevant ICA or CISI qualifications.A satisfactory fit and proper record.Sufficient capacity to fulfil the appointment.Technical knowledge alone is not enough. We want candidates who can explain difficult decisions they have made and demonstrate how they protected the firm.FCA approval and accountabilitySMF16 is a pre-approval function. The individual cannot begin performing the approved role until the FCA has granted approval.The process includes a Form A submitted through Connect, a Statement of Responsibilities and supporting fit and proper information.Under SMCR, the individual is personally accountable for their responsibilities. They must be able to demonstrate that they took reasonable steps to discharge them.The reporting structure matters too. The SMF16 holder needs appropriate access to the board, sufficient authority and the independence to raise concerns.Why SMF16 recruitment can be difficultThe pool of experienced candidates is relatively small. Many of the strongest professionals are already employed or engaged in fractional appointments.Firms can also underestimate the seniority required. Recruiting someone too junior may save salary initially, but create greater regulatory risk as the business develops.Capacity is another issue. A fractional appointment must have enough time allocated to complete the monitoring programme, reporting and other responsibilities properly.How FD Capital manages your searchWe begin by understanding the firm's permissions, business model, compliance workload and regulatory profile.We then approach our specialist network and assess candidates for experience, judgement, independence and availability.For fractional and interim appointments, we aim to present an initial shortlist within 72 hours. Permanent searches take longer.We recruit SMF16 professionals across payments and e-money, consumer credit, wealth management, investment management, insurance distribution and cryptoasset businesses.Every search is overseen by Adrian Lawrence FCA.Contact FD CapitalIf you need to appoint an SMF16, replace an existing Compliance Oversight holder or introduce fractional compliance leadership, contact our team for a confidential discussion.Telephone: 020 3287 9501Email: [email protected]://www.fdcapital.co.uk/smf16-recruitment/FD Capital – specialist recruitment for FCA-regulated businesses.

fractional smf16 and smf17 recruitmentWelcome to FD Capital. We recruit fractional, interim and part-time SMF16 Compliance Oversight and SMF17 Money Laundering Reporting Officer professionals for FCA-regulated businesses.Many smaller firms do not need two full-time senior appointments. They need an experienced professional who can oversee compliance, manage financial crime responsibilities and provide effective challenge to the board.Find out more:https://www.fdcapital.co.uk/fractional-smf16-smf17-recruitment/Understanding the two functionsSMF16 is responsible for Compliance Oversight, including the firm's compliance arrangements, monitoring programme and regulatory obligations.SMF17 is the Money Laundering Reporting Officer, responsible for assessing internal suspicious activity reports and deciding whether a report should be submitted to the National Crime Agency.One individual can hold both functions where this is appropriate for the firm's size, nature and complexity. However, the responsibilities remain distinct. The person must have the experience, authority and time to perform both effectively.When does a combined appointment make sense?A fractional dual appointment can work well for smaller insurance brokers, mortgage firms, wealth managers, consumer credit lenders and early-stage payments businesses.Rather than employing two senior professionals full-time, a firm may engage one experienced individual for an agreed number of days each month.The arrangement is not suitable for every business. High transaction volumes, complex financial crime risks, significant compliance workloads or FCA remediation may justify separate appointments.As a firm grows, its original structure should be reviewed. What worked at authorisation may no longer provide adequate oversight several years later.What should the individual deliver?A fractional SMF16/17 professional may oversee:Compliance monitoring and regulatory reporting.Board advice and escalation of significant risks.Policies, procedures and staff training.FCA enquiries and supervisory engagement.Anti-money laundering controls.Internal suspicious activity reports and SAR decisions.The individual must be able to challenge directors independently and take responsibility for difficult regulatory decisions.How much time is required?Two or three days per month may be a reasonable starting point for a small, straightforward business. More complex firms will need greater availability.The engagement should clearly define working days, board attendance, deliverables, urgent availability and additional fees.There is no universal minimum commitment. The key question is whether the individual has enough time to discharge both functions properly.Finding the right candidateWe assess candidates on their previous SMF16 and SMF17 experience, sector knowledge, AML expertise, regulatory judgement and ability to communicate with boards.We also examine existing appointments and capacity. A professional may be technically excellent but unable to take on another responsibility effectively.Relevant qualifications are useful, but practical experience and sound judgement are essential.FCA approvalSMF16 and SMF17 are pre-approval functions. FCA approval must be obtained before the individual takes up the relevant responsibilities.The process involves a Form A, a Statement of Responsibilities and fit and proper assessment. Where one person holds both functions, the responsibilities must be clearly documented.Firms should plan ahead. FCA approval can take time, and finding an available candidate does not mean they can immediately start performing the approved functions.Succession planning is equally important. Losing one dual-function holder can leave a firm without approved cover for both responsibilities.How FD Capital helpsWe establish whether your firm needs a combined appointment or separate SMF16 and SMF17 professionals.We then approach our specialist network and assess candidates for experience, availability and suitability. For fractional and interim requirements, we aim to provide an initial shortlist within 72 hours.We recruit across payments, e-money, insurance, wealth management, investment management, consumer credit and lending.Contact FD CapitalIf your business needs fractional SMF16 Compliance Oversight, an SMF17 MLRO or one professional to cover both functions, contact our recruitment team.Telephone: 020 3287 9501Email: [email protected]://www.fdcapital.co.uk/fractional-smf16-smf17-recruitment/FD Capital – specialist recruitment for FCA-regulated businesses.

Senior recruitment is becoming increasingly specialised. Businesses and regulated firms need leaders and professionals who understand not only their job function, but also the financial, regulatory and commercial environment in which they operate.That is the thinking behind five specialist recruitment brands: CFO Capital, FD Capital Group, Regulatory Capital, MLRO Capital and Broker Recruit.Each has a distinct focus, while together they provide access to a broader network of specialist finance and financial-services professionals.CFO Capital – Specialist CFO RecruitmentCFO Capital focuses on CFO and senior finance leadership.Today's CFO does much more than oversee accounts. The role can involve financial strategy, cash management, forecasting, fundraising, acquisitions, investor relationships, systems, risk management and building the finance function.A growing business may need a permanent CFO, while another may need an interim or fractional CFO during a period of rapid growth, restructuring, investment or acquisition.The important point is matching the CFO's experience to the company's actual requirements.A start-up preparing for investment can require a very different CFO from an established international business undertaking an acquisition.Specialist recruitment allows those differences to be understood before the search begins.FD Capital Group – The Wider Finance Leadership NetworkFD Capital Group provides a broader specialist network covering senior finance and executive recruitment.Finance Director requirements vary enormously between businesses.A growing SME may need a commercially minded Finance Director to establish stronger controls and reporting. A larger organisation may require international experience, acquisition expertise or the ability to manage a substantial finance team.There are also businesses where a fractional or interim Finance Director is the most appropriate solution.The value of specialist recruitment is that the search can be built around the business challenge rather than simply matching keywords on a CV.The strongest finance leaders understand the numbers, but also help management understand what those numbers mean for the future.Regulatory Capital – Specialist Prudential ExpertiseRegulatory Capital focuses on specialist finance and prudential expertise within regulated financial services.Regulated firms may need to manage capital requirements, liquidity, regulatory reporting, stress testing and other requirements specific to their regulatory framework.The precise requirements differ between different types of regulated businesses. An investment firm, payments business, insurer or other financial services organisation can face very different capital considerations.This means conventional finance experience may not be enough.A regulatory capital professional needs to understand the interaction between financial management, prudential regulation and the commercial operation of the business.This specialist expertise can be particularly valuable when a regulated business is growing, changing its permissions, preparing for authorisation or dealing with increasing regulatory complexity.MLRO Capital – Specialist Financial Crime RecruitmentMLRO Capital focuses specifically on senior Money Laundering Reporting Officer and financial crime recruitment.The MLRO has a critical position within many regulated businesses and may oversee areas including suspicious activity reporting, customer due diligence, transaction monitoring, sanctions, financial crime risk assessments and regulatory engagement.This is not simply another compliance appointment.The MLRO needs sufficient expertise, authority and independence to challenge the business and escalate concerns when required.MLRO Capital allows firms to search specifically for professionals with genuine financial crime and regulatory experience rather than relying on a generalist recruitment process.As financial crime risks evolve and regulatory expectations increase, the quality of the MLRO appointment can have a significant effect on the firm's control environment.Broker Recruit – Specialist Stockbroker RecruitmentBroker Recruit adds another specialist discipline to the network, focusing on recruitment within the stockbroking and brokerage sector.Financial markets businesses require professionals who understand the specialist environment in which brokers operate.Recruitment can involve candidates with experience across broking, dealing, investment and related financial-services functions.This is an area where industry knowledge can be particularly valuable.A candidate may have excellent general financial-services experience but lack the specific understanding of brokerage, market structure, clients and the regulatory environment required by a particular firm.Broker Recruit provides a dedicated specialist destination for businesses seeking talent within this market.Why Specialist Recruitment MattersAlthough these five businesses have different areas of focus, they share a common principle.Senior and specialist recruitment should begin with understanding what the business actually needs.A CFO might be required to lead a fundraising exercise.A Finance Director might need to rebuild a finance function.A regulatory capital specialist might need to strengthen prudential reporting.An MLRO might need to improve the firm's financial crime framework.A broker may need specialist experience of the markets and clients in which the business operates.These are very different challenges.Simply searching for someone with the right job title is unlikely to produce the best result.Sector experience, technical expertise, leadership ability and understanding of the relevant regulatory environment can all be critical.Permanent, Interim and Fractional ExpertiseBusinesses increasingly want flexibility in how they access senior expertise.An interim CFO can provide immediate leadership while a permanent appointment is made.A fractional Finance Director can support an SME without requiring a full-time appointment.A regulatory specialist can assist during an authorisation or prudential project.An interim MLRO can provide continuity when a permanent MLRO leaves.Specialist recruitment can therefore provide access to experienced professionals at precisely the point a business needs them.One Connected Specialist NetworkThere is also considerable overlap between these disciplines.A growing regulated financial-services business might need a CFO with financial-services experience, specialist regulatory capital expertise and an experienced MLRO.A brokerage could require specialist senior finance leadership alongside experienced brokers and compliance professionals.Those individuals have different responsibilities, but they ultimately need to work together.The ability to access specialist recruitment expertise across connected disciplines can therefore be valuable to clients.ConclusionCFO Capital focuses on CFO leadership.FD Capital Group provides a wider senior finance and executive recruitment network.Regulatory Capital focuses on specialist prudential and regulatory finance expertise.MLRO Capital focuses on senior financial crime and MLRO recruitment.Broker Recruit focuses on specialist recruitment within the stockbroking and brokerage market.Together, these specialist businesses provide access to expertise across finance, regulation, financial crime and financial markets.Whether the requirement is permanent, interim or fractional, the objective remains the same: understand the business first and then identify the professional with the experience, technical knowledge and judgement to make a genuine difference.For businesses operating in complex financial and regulated environments, specialist recruitment can provide a significant advantage.

Today we are looking at an issue that can create an immediate problem for regulated financial services businesses: what happens when an SMF16 Compliance Oversight or SMF17 Money Laundering Reporting Officer becomes unavailable?A senior compliance professional may resign, take extended leave, become temporarily unable to perform their role, or leave the business unexpectedly. The firm still has to operate, customers still need to be protected, financial crime risks still need to be managed and regulatory obligations do not stop simply because a key individual has left.This is where temporary SMF cover can become extremely important.To find out more about FD Capital's specialist service, visit:https://www.fdcapital.co.uk/smf16-smf17-temporary-cover-12-week-rule/What is the 12-week rule?The FCA's rules provide a mechanism that can allow a firm to arrange temporary cover when an individual performing a senior management function is unexpectedly absent.This is commonly referred to as the 12-week rule.The purpose is to give a firm time to manage an unexpected absence without leaving an important senior management responsibility unattended while a longer-term solution is put in place.However, firms should not treat the 12-week rule as a way of avoiding the normal approval requirements for SMF appointments. The rules have specific conditions and limitations, and firms need to establish whether their particular circumstances qualify.The person providing temporary cover must also be capable of performing the responsibilities being allocated to them.That is why specialist interim recruitment can be valuable when an SMF16 or SMF17 suddenly becomes vacant.Why an SMF vacancy needs a rapid responseA compliance vacancy is different from many ordinary recruitment situations.The business continues operating while the vacancy exists. Compliance monitoring continues, regulatory developments continue and financial crime risks remain.The board therefore needs to establish quickly who is responsible for the relevant function.Can an existing senior manager provide appropriate cover?Does the current compliance team have sufficient experience and capacity?Is an interim specialist required?And how quickly can a suitable permanent replacement be found?These decisions become particularly important where the firm is highly regulated, undergoing rapid growth or dealing with regulatory change.Leaving responsibilities unclear while a permanent recruitment process takes place can create unnecessary risk.Temporary SMF16 coverSMF16 is the Compliance Oversight function.Depending on the nature of the firm, the role can involve oversight of compliance monitoring, regulatory change, conduct risk, Consumer Duty, financial promotions and the escalation of significant compliance issues.If the existing SMF16 leaves unexpectedly, an interim professional can provide continuity while the business recruits permanently.The interim SMF16 needs to understand the firm's regulatory framework quickly and identify the areas requiring immediate attention.They may need to review outstanding compliance monitoring actions, audit findings, regulatory developments, risk registers and issues previously escalated to senior management.The objective is not simply to put a name against the position.The temporary individual

Welcome to the FD Capital podcast, where we explore finance leadership, financial services recruitment, regulatory change and the people who help businesses grow while managing risk effectively.Today, we are looking at an increasingly important area of financial services: payments and e-money compliance recruitment. We will discuss why payment institutions and electronic money institutions need experienced compliance leadership, the challenges facing firms under the FCA's regulatory framework, and how to find the right Head of Compliance, Money Laundering Reporting Officer or Head of Safeguarding.We will also explore the differences between permanent, interim and fractional compliance appointments, and why recruitment decisions made during authorisation or a period of rapid growth can have a lasting impact on a business.If you operate a payment institution, an electronic money institution, a card programme, an open banking business or an embedded payments platform, this episode should be particularly relevant.Why payments compliance has become a board-level priorityThe payments industry has evolved considerably. New technology, faster transactions, embedded finance and the expansion of digital payment services have created opportunities for innovative businesses. However, these developments have also increased the importance of effective compliance, financial crime prevention and safeguarding.Payment firms must demonstrate that they understand their regulatory obligations and have appropriate people, systems and controls in place. It is not sufficient to have a policy document sitting on a shared drive. Compliance arrangements must work in practice, reflect the firm's business model and remain effective as transaction volumes increase.For founders and boards, this creates a significant leadership challenge. They need compliance professionals who understand the regulatory framework but can also work alongside commercial teams, product developers, operations and finance.The right individual must be able to identify risk, challenge decisions where necessary and help the business develop a proportionate control environment. They must understand that a growing payments business needs commercial momentum, but that growth cannot come at the expense of customer protection, financial crime controls or regulatory obligations.This is one reason experienced payments compliance professionals are so valuable. Finding somebody with the right combination of technical knowledge, practical experience and judgement is not always straightforward.The impact of the strengthened safeguarding regimeSafeguarding is a particularly important issue for payment institutions and electronic money institutions.The FCA's strengthened safeguarding regime took effect on 7 May 2026, bringing additional requirements for relevant firms. These include daily safeguarding reconciliations on business days, monthly safeguarding returns, annual safeguarding audits subject to applicable exemptions, and a resolution pack documenting where relevant funds are held and how they are managed.For firms, these requirements reinforce the importance of clearly defined ownership, reliable information and effective oversight.Safeguarding is not simply an accounting exercise. It requires coordination between finance, operations, compliance and senior management. Reconciliations need to be performed appropriately, discrepancies investigated, records maintained and weaknesses escalated.This is creating a stronger case for dedicated safeguarding expertise in firms where the scale, complexity or risk profile justifies it.Some businesses may need a Head of Safeguarding with responsibility for the overall framework. Others may need a compliance leader who understands safeguarding in sufficient depth to oversee the arrangements, challenge weaknesses and work effectively with the finance function.When recruiting for these positions, employers should look beyond job titles. They should ask candidates to explain how they have managed safeguarding processes, prepared for audits, resolved reconciliation problems and improved controls following a review.Practical experience matters. A candidate who has worked through a safeguarding remediation exercise may bring valuable insight that is difficult to assess from a CV alone.Finding the right Head of Compliance and MLROTwo of the most important appointments for a payments business are the Head of Compliance and the Money Laundering Reporting Officer, commonly known as the MLRO.At smaller and early-stage firms, these responsibilities are often combined in one position. That can be a sensible arrangement, provided the individual has sufficient seniority, expertise, time and support to discharge both responsibilities effectively.As the business expands, the workload can become more demanding. Transaction volumes increase, new products are introduced, additional partners are appointed and financial crime risks evolve. A structure that worked for a small start-up may no longer be appropriate for a larger, more complex organisation.An effective Head of Compliance should understand the relevant regulatory requirements, oversee compliance monitoring and maintain an appropriate relationship with the regulator. The role also requires the ability to communicate clearly with the board and translate regulatory expectations into practical actions.The MLRO has a distinct focus on the firm's anti-money laundering arrangements, suspicious activity reporting and wider financial crime framework. The individual needs to understand the firm's risk assessment, customer due diligence, transaction monitoring and escalation procedures.For payments firms, financial crime expertise should extend beyond traditional money laundering risks. Fraud, sanctions exposure, money mule activity and the misuse of payment services all require careful consideration.Employers should also assess whether candidates have experience relevant to their particular operating model. A professional who has worked at a traditional bank may have strong technical knowledge, but experience at a payment institution, EMI or card programme manager may be more directly applicable to a fast-moving payments business.The objective is not simply to recruit somebody who knows the rules. It is to find somebody who can apply them effectively within the organisation.Understanding the difference between payments regulation and SM&CRAnother important recruitment consideration is the regulatory structure under which the business operates.Payment institutions and electronic money institutions authorised solely under the Payment Services Regulations 2017 or the Electronic Money Regulations 2011 generally sit outside the Senior Managers and Certification Regime. Their compliance and MLRO arrangements therefore do not automatically map onto the SMF16 and SMF17 designations used by firms within SM&CR.However, where a payments business or its group also operates an entity with relevant FSMA permissions, the position can become more complicated.For example, a group might combine an EMI with a lending business or an investment-related entity. In these circumstances, the responsibilities and approval requirements applicable to each legal entity need to be considered carefully.This matters when recruiting because candidates must understand the actual regulatory responsibilities attached to the role, rather than relying on familiar job titles.Someone who has operated successfully as an SMF16 or SMF17 in an investment firm may bring valuable governance experience, but they still need to demonstrate an understanding of the payments environment. Equally, a payments compliance specialist may need additional experience if the role includes responsibilities within an SM&CR-regulated entity.A good recruitment process examines these differences at the outset, helping the employer identify the experience genuinely required for the appointment.Financial crime, fraud and operational expertiseFinancial crime controls are another major consideration for payment institutions.A strong compliance or MLRO candidate should be able to discuss how customer risk assessments are developed, how transaction monitoring is calibrated, how sanctions screening operates and how suspicious activity is escalated.They should also understand the practical challenges of operating these controls at scale.For example, a monitoring system that generates excessive false positives can overwhelm an investigations team and make it harder to identify genuine concerns. Conversely, poorly designed controls can fail to identify suspicious activity that should have been investigated.The challenge is to build a system that is proportionate to the firm's risks while remaining effective as its customer base, products and transaction volumes change.Experience working with technology teams can therefore be particularly valuable. Compliance professionals increasingly need to understand data, systems and operational workflows, and to explain the controls required in a way that product managers and engineers can implement.Partner oversight is equally important. Embedded payments, banking-as-a-service arrangements and card programmes may involve agents, distributors, sponsor banks and other third parties. The compliance function needs to understand these relationships, establish appropriate oversight and ensure that responsibilities are clear.When interviewing candidates, employers should ask for specific examples of controls they have designed, weaknesses they have identified and improvements they have implemented. This provides a more

Welcome to the FD Capital podcast. Today, we’re discussing consumer credit compliance recruitment and why the right compliance leaders matter for lenders, Buy Now Pay Later (BNPL) providers, point-of-sale finance firms and growing fintech businesses.Find out more about FD Capital’s service:https://www.fdcapital.co.uk/consumer-credit-compliance-recruitment-smf16-smf17-and-compliance-leadership-for-lenders-bnpl-providers-and-point-of-sale-finance-firms/Why specialist compliance recruitment mattersConsumer lenders need to develop products, reach customers and make lending decisions efficiently while maintaining appropriate governance and controls. As a business grows, its responsibilities become more complex: products change, transaction volumes rise, distribution partners multiply and customer needs evolve.An effective compliance leader turns regulatory requirements into practical processes. That means monitoring whether policies work, identifying weaknesses, reporting risks to senior management and supporting a culture in which customers are treated fairly.Recruiting someone with relevant experience is important. A candidate who understands the rules but has little experience of the firm's type of lending may need considerable support. Someone who has worked in a comparable lender or BNPL business may be better placed to recognise risks and address them.BNPL and the changing regulatory environmentBuy Now Pay Later has become an important part of online retail and point-of-sale finance. The model gives customers another way to spread payments, but providers must consider

Today we're announcing the launch of something new from the FD Capital group: SMF Capital, a specialist recruitment practice dedicated to Senior Manager Function appointments within UK financial services.The new business is now live at www.smfcapital.co.uk.So why have we launched SMF Capital, and what does it offer regulated firms?Why SMF Capital?Since FD Capital was founded in 2018, we've specialised in recruiting Finance Directors, CFOs and senior finance professionals, including fractional and interim appointments.As that business has grown, we've increasingly worked with FCA-regulated firms where the senior appointment carries an additional dimension: regulatory accountability.A CFO may be an SMF2. A senior compliance professional may hold SMF16 or SMF17. A Chief Risk Officer may be an SMF4. A Chair or other board-level appointment may also carry an SMF designation.These aren't ordinary executive appointments.The individual may need regulatory approval before taking up the function, and the firm needs to be satisfied that the candidate is fit and proper for the responsibilities involved.We therefore decided that SMF recruitment deserved its own specialist practice.What Does SMF Capital Do?SMF Capital recruits Senior Manager Function holders for FCA and PRA-regulated firms.The practice covers executive and non-executive appointments, permanent, interim and fractional recruitment.It works with a wide range of regulated businesses, including wealth and investment managers, consumer credit firms, insurers and intermediaries, banks and building societies, payments and fintech businesses, and overseas firms establishing UK operations.The focus is not simply on finding somebody with an impressive CV.The recruitment process is built around the question:Is this person genuinely suitable for the specific regulatory responsibility they are being asked to take on?That means considering their previous experience, sector knowledge, leadership capability and readiness for personal regulatory accountability.The Regulator's Test Starts at the BeginningOne of the ideas behind SMF Capital is that the regulator's fit and proper assessment shouldn't be treated as something that happens at the very end of recruitment.It should influence the search from the beginning.For example, a candidate might have extensive compliance experience but very limited experience in the particular type of regulated business they are being asked to oversee.Another candidate might have excellent technical credentials but insufficient seniority or experience of exercising the judgement required by the role.A conventional recruitment process can miss these distinctions.SMF Capital aims to identify them early.Every search is led personally by Adrian Lawrence FCA, rather than being handed to a junior consultant part way through the process.Permanent, Interim and Fractional SMFsNot every regulated business needs a full-time senior manager.A smaller firm might require an experienced compliance professional or MLRO for only part of the working week.Another business may need an interim senior manager following an unexpected departure.A newly authorised firm may need senior leadership in place while it develops its permanent structure.SMF Capital therefore covers permanent, interim and fractional appointments.The important point is that a fractional or interim arrangement still needs to provide the individual with sufficient time, authority and resources to perform their responsibilities effectively.SMF Authorisation SupportSMF Capital also helps firms preparing for FCA authorisation.For a new regulated business, recruiting the right senior managers can be one of the most important parts of building the organisation.The people named in an application need to be capable of performing the responsibilities assigned to them.SMF Capital can help firms identify appropriate candidates and build the recruitment process around the regulatory timetable.This can be particularly valuable for fintechs, investment businesses and other firms building their management team from scratch.Governance and SMF StructureThe business also provides support with governance and SMF structures.As a regulated firm grows, its responsibilities can change.A business may become more complex, move into a different regulatory category, introduce new activities or restructure its senior management team.At that point, it is worth asking whether the firm's SMF structure still reflects how the business actually operates.Who is responsible for each area?Are responsibilities clearly allocated?Does the firm's documentation accurately reflect reality?And do the people holding those responsibilities have sufficient experience and capacity?These questions are at the heart of effective senior management governance.Who Is Behind SMF Capital?SMF Capital was founded by Adrian Lawrence FCA, who also founded FD Capital.Adrian is a Fellow of the ICAEW, holds an ICAEW practising certificate and is a former listed-company Finance Director with more than 25 years' experience as a Chartered Accountant and finance leader.FD Capital remains focused on Finance Directors and CFOs, while the wider specialist network includes Exec Capital, NED Capital and Accountancy Capital.SMF Capital is the latest addition, concentrating specifically on Senior Manager Function appointments.This specialist structure means that if a client needs an SMF2 CFO, a senior compliance appointment, a board appointment or another regulated senior role, the requirement can be directed to the most appropriate specialist practice.Why Is This Important for FD Capital?For FD Capital, the launch of SMF Capital is a natural extension of the business.Finance leadership and regulatory leadership increasingly overlap.A regulated firm may need a CFO who understands both finance and the responsibilities associated with SMF2.A growing business may need a fractional compliance officer alongside its finance leadership.A board restructuring may involve several senior appointments at the same time.Rather than treating these as generic executive recruitment assignments, the new network provides specialist expertise across the different areas.A New Resource for the SM&CRSMF Capital isn't just a recruitment business.The website also includes a Knowledge Centre, covering subjects such as the fit and proper test, regulatory references, firm tiers, the Conduct Rules, the 12-week rule and the practical mechanics of SMF appointments.There's also SMF Unlocked, a dedicated podcast exploring the Senior Managers Regime and the practical issues faced by firms and senior managers.The aim is to make SMF Capital a useful resource for boards, compliance teams, HR professionals, candidates and businesses preparing for authorisation.Who Should Visit SMF Capital?If you're a regulated firm recruiting a Senior Manager, the website is designed for you.If you're preparing an FCA authorisation application and need to build a senior management team, it's relevant to you.If you're looking for interim or fractional compliance, risk or other SMF support, it's also relevant.And if you're already an experienced Senior Manager considering your next appointment, SMF Capital provides a confidential way to register with a specialist recruiter.Many of the senior appointments handled by specialist recruiters are never publicly advertised.Visit SMF CapitalSo, if you work in UK financial services and have a Senior Manager Function recruitment requirement, visit:www.smfcapital.co.ukYou'll find information about the different SMFs, recruitment services, interim and fractional appointments, authorisation support, governance reviews and current opportunities.And if you're not sure whether your requirement is actually an SMF appointment, you can contact the team and discuss it.Final ThoughtsThe launch of SMF Capital reflects something we've seen repeatedly through FD Capital's work with regulated businesses.A Senior Manager appointment isn't simply another senior recruitment assignment.The individual may carry personal regulatory accountability for a defined area of the business, and the firm needs confidence that the person appointed is genuinely capable of carrying that responsibility.That means the regulatory dimension needs to be considered from the beginning of the recruitment process.That's why we've created SMF Capital.It's a specialist practice focused on Senior Manager Function recruitment for regulated firms, covering permanent, interim and fractional appointments as well as authorisation and governance support.So, from everyone at FD Capital, we're delighted to announce the launch of SMF Capital.Visit www.smfcapital.co.uk to find out more.Thank you for listening to the FD Capital Podcast.

Welcome to the FD Capital Podcast, where we explore finance leadership, fractional executives and the changing needs of businesses across the UK.Today we're looking at an increasingly important option for FCA-regulated firms: fractional compliance officers.Every regulated business needs effective compliance leadership. But does every firm really need a full-time Head of Compliance or Chief Compliance Officer?That's the thinking behind fractional compliance.What Is a Fractional Compliance Officer?A fractional compliance officer is an experienced compliance professional who works for a firm on a part-time, ongoing basis.Why Is the Model Becoming More Attractive?There are several reasons.The first is cost.A small regulated firm may need the expertise of a senior compliance professional but may not have enough work to justify a six-figure full-time appointment.The second is access to experience.A fractional professional may have previously held senior compliance or MLRO positions across several regulated businesses. A smaller firm can therefore gain access to experience that would otherwise be difficult to recruit on a full-time basis.The third is flexibility.A business might initially require one day a week. As it grows, adds permissions, launches products or becomes more complex, the commitment can increase.Fractional, Outsourced and Interim Are Not the SameThese terms are sometimes used interchangeably, but they can describe quite different arrangements.Fractional generally means a named senior individual working for the firm on an ongoing part-time basis.Outsourced compliance usually means the firm engages an external consultancy to provide compliance services, potentially using several members of its team.Interim normally means an experienced individual comes into the business for a defined period, often to cover a vacancy, remediation programme or transition.The distinction matters particularly where an SMF is involved.An SMF is a function performed by an individual. The firm needs to understand exactly who is responsible, what authority they have and whether they have sufficient time and resources to perform the role properly.SMF16 and SMF17Two particularly relevant functions are SMF16 Compliance Oversight and SMF17 Money Laundering Reporting.For smaller firms, it may be possible for one appropriately qualified individual to perform both functions, depending on the firm's circumstances.This can make a fractional model particularly attractive.The individual needs sufficient time and support to carry out the responsibilities effectively.How Many Days a Week Do You Need?There is no universal answer.A small directly authorised IFA with relatively straightforward activities might require considerably less senior compliance time than a rapidly growing payments or investment business.A boutique investment manager might need one or two days each week.A newly authorised lender or payments business may need substantially more support while its systems and controls mature.A firm that has suddenly lost its Head of Compliance might also use a fractional professional as a bridge while recruiting a permanent replacement.The important question is not:"How cheaply can we cover compliance?"It is:"How much senior compliance resource does our business genuinely require?"That is a much better starting point.The exact responsibilities should be clearly defined in the firm's governance arrangements and, where applicable, the individual's Statement of Responsibilities.The Importance of Sector ExperienceOne of the biggest mistakes a regulated business can make is assuming that any experienced compliance professional will automatically be suitable.Compliance is highly sector-specific.An SMF16 working for an IFA needs to understand the regulatory environment around financial advice, suitability and the firm's particular business model.A compliance leader for a payments firm needs different experience.An investment manager will have different requirements again.The best fractional appointment is therefore usually someone who has already worked in a business with a similar regulatory profile.That allows them to contribute quickly rather than spending months learning the firm's sector from scratch.What Makes a Good Fractional Compliance Leader?There are several characteristics to look for.Relevant SMF experience is highly valuable, particularly where the individual will be expected to hold an SMF16 or SMF17 function.Sector experience is equally important. A candidate should understand the regulatory environment in which the firm actually operates.Board presence matters too. A fractional compliance officer may only be in the business one day a week, but they still need the confidence to challenge directors when necessary.Efficiency is essential. Someone working fractionally has limited time and needs to prioritise the highest-risk issues.And finally, capacity and conflicts need to be considered.Many fractional compliance professionals work with several firms. That can be a strength because they bring broad experience, but the firm needs confidence that the individual has enough capacity to perform its particular role effectively.The Financial CaseThe economics can be compelling.A firm might pay a senior fractional compliance professional a day rate for one or two days a week rather than employing a full-time executive with salary, pension, employer National Insurance, bonus and other employment costs.FD Capital's current fractional compliance recruitment market includes senior professionals working at approximately £600–£1,100 per day depending on seniority, sector and complexity. Actual rates vary significantly by individual and requirement.That means a smaller regulated business can potentially obtain senior compliance expertise for a fraction of the cost of a full-time appointment.But the financial calculation should always come second to determining what level of compliance resource the firm actually needs.When Should a Firm Consider Going Full-Time?Fractional compliance isn't necessarily the end state.As a business grows, there may come a point where a full-time Head of Compliance or Chief Compliance Officer makes more sense.Potential triggers include:rapidly increasing customer numbers;additional regulatory permissions;new products or business lines;increased financial crime exposure;growing compliance monitoring requirements;increased FCA engagement;a move towards greater organisational complexity;or simply the point where the fractional professional is consistently working beyond the agreed commitment.The fractional model can therefore act as a bridge between having too little senior compliance resource and building a full-time compliance function.How FD Capital HelpsFD Capital brings the fractional model that has traditionally been associated with Finance Directors and CFOs into the wider regulated business environment.We recruit fractional Heads of Compliance, Compliance Officers, MLROs and senior compliance professionals for FCA-regulated businesses.Our approach starts with understanding the firm's regulatory perimeter, permissions, activities, size, risk profile and the support already available internally.We then identify candidates with the relevant sector and regulatory experience rather than simply searching for anyone with "compliance" on their CV.For fractional appointments, FD Capital says it aims to provide a shortlist within 48 to 72 hours of receiving a full brief, with the subsequent appointment and regulatory approval process depending on the individual and circumstances.Fractional compliance can provide a more flexible alternative.Find Out MoreIf your business needs senior compliance expertise but isn't ready for a full-time appointment, FD Capital can help you explore the fractional model.We've created a dedicated guide covering fractional compliance officer recruitment, including SMF16, SMF17, the difference between fractional and outsourced compliance, typical time commitments and the recruitment process.You can read it here:Fractional Compliance Officer RecruitmentIf you're considering recruiting a fractional Head of Compliance, SMF16, MLRO or combined compliance and financial crime leader, the team at FD Capital can discuss your requirements and the level of support your firm actually needs.For many smaller FCA-regulated firms, that could be a highly practical and commercially sensible model.If your firm needs senior compliance expertise without immediately committing to a full-time appointment, take a look at FD Capital's Fractional Compliance Officer Recruitment service.Thank you for listening to the FD Capital Podcast. Join us next time as we explore another issue affecting finance, compliance and senior leadership in UK businesses.

Welcome back to The Regulatory Leadership Podcast.Today we're tackling one of the most significant regulatory developments to impact UK financial services in recent years: Consumer Duty.If you're a Chief Compliance Officer, Risk Director, Board Member, Head of Compliance, or anyone involved in FCA-regulated businesses, you'll know that Consumer Duty is no longer an implementation project. It's now a permanent part of how firms are expected to operate.The challenge facing many organisations today isn't understanding what Consumer Duty is.The challenge is proving that it's working.In this episode we'll explore:Why Consumer Duty changed the regulatory landscapeThe four customer outcomes firms must deliverCommon implementation mistakesWhat the FCA is focusing on nowWhy specialist compliance talent has become criticalAnd we'll highlight an excellent resource from FD Capital called Consumer Duty: The Complete UK Guide, which provides a detailed practical explanation for firms navigating these requirements.Let's get started.Segment 1: The Biggest Regulatory Shift in a DecadeConsumer Duty represents a fundamental shift in regulatory philosophy.Historically, financial services firms focused heavily on process compliance. The question regulators often asked was:"Did the firm follow the rules?"Under Consumer Duty, the question has become:"Did the customer achieve a good outcome?"That's a major difference.A firm can follow procedures, provide disclosures, complete assessments, and still face regulatory scrutiny if customer outcomes are poor.The FCA introduced Principle 12, requiring firms to act to deliver good outcomes for retail customers. This is supported by three cross-cutting rules:Act in good faithAvoid foreseeable harmSupport customers in pursuing their financial objectivesFor many organisations, this has required a complete rethink of governance, customer monitoring, reporting, and accountability.Segment 2: Understanding the Four Consumer Duty OutcomesLet's briefly walk through the four outcomes that sit at the heart of Consumer Duty.Outcome 1: Products and ServicesProducts must be designed for a clearly identified target market and distributed appropriately.Firms need ongoing evidence that products continue to meet customer needs and objectives. This isn't a one-off exercise. It requires continuous review and oversight.Outcome 2: Price and ValueThe FCA expects firms to demonstrate that customers receive fair value.Importantly, fair value doesn't mean lowest price.It means the benefits received are proportionate to the cost being paid by customers. Firms need robust methodologies to assess this and challenge pricing where necessary.Outcome 3: Consumer UnderstandingCommunications must be clear, understandable, and effective.The FCA increasingly expects firms to test customer communications and demonstrate that customers genuinely understand key information rather than simply receiving it.Outcome 4: Consumer SupportCustomers should be able to access support when needed and use products effectively.This includes complaint handling, service accessibility, vulnerable customer support, and ensuring barriers don't prevent customers from achieving their financial goals.Segment 3: Why Many Firms Are Still StrugglingOne of the most interesting insights from FD Capital's Consumer Duty Guide is that many firms treated Consumer Duty as a compliance project rather than a business transformation.And that's where problems often begin.Documentation was created.Committees were established.Policies were updated.But customer outcomes weren't always measured effectively.The ongoing challenge is evidence.Can you demonstrate:Customers are receiving fair value?Communications are understood?Vulnerable customers are being supported?Outcomes monitoring drives action?Because increasingly, that's what regulators want to see.Segment 4: The FCA's Focus in 2026Recent FCA commentary suggests firms are improving the quality of their Consumer Duty reporting.Boards are receiving more structured information, accountability is becoming clearer, and action plans are increasingly linked to measurable outcomes.However, the FCA continues to focus on:Outcomes monitoringGovernance effectivenessFair value assessmentsVulnerable customer treatmentBoard engagementEvidence of remediation when issues are identifiedThe key message is simple.Data alone is not enough.Management information must lead to action.If a problem is identified, firms are expected to demonstrate how they responded and improved outcomes.Segment 5: The Talent ChallengeOne of the less discussed consequences of Consumer Duty has been the growing demand for specialist compliance professionals.Many firms now require:Heads of Consumer DutyConsumer Duty AnalystsChief Compliance OfficersRisk DirectorsConduct Risk SpecialistsRegulatory Reporting LeadersThese are increasingly strategic positions that sit at the intersection of regulation, customer outcomes, governance, and business performance.The organisations succeeding under Consumer Duty are often those with strong leadership, robust governance structures, and experienced professionals who understand both regulatory expectations and commercial realities.Segment 6: Recommended ResourceIf today's discussion has raised questions about your own Consumer Duty framework, I strongly recommend reading FD Capital's comprehensive guide:Consumer Duty: The Complete UK GuideThe guide covers:Principle 12The three cross-cutting rulesThe four outcomesBoard governance requirementsOutcomes monitoringCommon implementation failuresFCA supervisory expectationsSpecialist compliance rolesIt's one of the more practical and detailed explanations available for senior leaders working within FCA-regulated firms.You can read it here:FD Capital Consumer Duty GuideClosing ThoughtsConsumer Duty has fundamentally changed the conversation around compliance.The focus has shifted from demonstrating that rules were followed to proving that customers achieved good outcomes.That's a higher standard.It's also a more meaningful one.The firms that thrive under Consumer Duty won't simply be those with the best documentation.They'll be the firms with the strongest customer focus, the best governance, the most effective monitoring, and the right people leading the effort.Thank you for listening to The Regulatory Leadership Podcast.If you found this episode useful, please subscribe, leave a review, and share it with colleagues working in compliance, risk, governance, and financial services leadership.Until next time, stay compliant and stay customer-focused.