Compliance news and senior manager recruitment for FCA-regulated firms, from SMF Capital and FD Capital Group

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For FCA-regulated firms

Compliance insight and senior manager recruitment for regulated firms

Regulatory Capital publishes news, guidance and practical resources on the Senior Managers and Certification Regime, compliance oversight, financial crime and FCA authorisation. When you need to hire, SMF Capital and its sister firms recruit for every senior manager function.

Hiring now? Call SMF Capital on 0203 745 0239

Searches led by Adrian Lawrence FCA Regulated appointments since 2018 Permanent, interim and fractional senior managers
About Regulatory Capital

Where regulation meets the people who carry it

Every FCA-regulated firm runs on two things: the rules it has to follow and the people who are personally accountable for following them. Most compliance publications cover the first and ignore the second. Regulatory Capital covers both. Our articles explain what is changing in UK financial services regulation, and then ask the question boards actually face next: who do we need, how senior, how many days a week, and how quickly can they be approved?

The site is written for boards, chief executives, founders preparing for authorisation, compliance officers and MLROs, and the finance and HR teams who support them. It is published by the team behind SMF Capital, a specialist recruiter for FCA senior manager functions, and its sister firms in The Capital Recruitment Group. That means the guidance comes from people who see senior manager appointments every week, not from a summary of the Handbook.

Under the Senior Managers and Certification Regime, an approved individual is personally answerable for the parts of the business they hold. Getting those appointments right is one of the most consequential decisions a regulated firm makes, and one of the easiest to get wrong under time pressure.

What you will find here

  • News and analysis on SMCR reform, financial crime, Consumer Duty, cryptoassets, payments and consumer credit
  • Function-by-function hiring guidance in our SMF recruitment guide
  • A directory of official sources and a running digest of regulatory change on our resources page
  • Podcasts on senior manager appointments, led by SMF Unlocked, on our podcasts page
  • Specialist recruitment for every senior manager function through SMF Capital and its sister firms
Latest articles

News and guidance for regulated firms

Practical articles on senior manager functions, compliance oversight, financial crime and the people regulated firms need to hire.

Specialist SMF recruitment

Why senior manager hiring needs a specialist

A senior manager appointment is not an ordinary senior hire with a regulatory form at the end. The individual must pass the FCA’s fitness and propriety assessment, their regulatory references must cover the past six years, and the firm must be able to show that they have the time, experience and support to do the job.

Generalist recruiters tend to treat the approval as somebody else’s problem. A candidate who looks right on paper can still stall at the FCA if their experience does not match the function, if a reference raises questions, or if the time commitment they offer is not credible for the firm’s size and risk. Those delays cost money, and for a firm in authorisation they can push back the date it is able to trade.

That is why SMF Capital exists. It is the group’s dedicated recruiter for FCA senior manager functions, set up to cover the whole regime in one place, from a first Compliance Officer and MLRO for a newly authorised payments firm to a chair, a chief risk officer and committee chairs at a firm moving from Core to Enhanced status. It runs permanent searches, interim cover when a holder leaves at short notice, and fractional arrangements where an experienced senior manager works for the firm part-time.

Demand is strongest for combined compliance oversight and money laundering reporting. At smaller firms one individual often holds both SMF16 and SMF17, and SMF Capital has a dedicated page on combined Compliance Officer and MLRO recruitment. For the background to that decision, read our article on whether to appoint one person for both roles, and our piece on building the financial crime team around your MLRO.

SMF Capital

Specialist recruitment for every FCA senior manager function

SMF Capital is the group's dedicated senior manager recruiter. It runs permanent, interim and fractional searches for regulated firms, from a first Compliance Officer and MLRO for a newly authorised firm to a board chair at an Enhanced firm. Every search is led personally by Adrian Lawrence FCA.

Or call 0203 745 0239

The Capital Recruitment Group

FCA-regulated hiring at every level

Senior managers come from very different talent pools. Alongside SMF Capital, four sister firms each recruit for regulated firms at a different level of leadership.

FD Capital

Finance and compliance leadership

Fractional, interim and permanent finance leaders for FCA-regulated firms, plus compliance and MLRO appointments.

Visit FD Capital

Exec Capital

C-suite and executive SMFs

C-suite and board-level appointments, including the executive senior managers of regulated firms.

Visit Exec Capital

NED Capital

Chairs and non-executives

Chairs, independent non-executive directors and committee chairs who hold governance functions under the SMCR.

Visit NED Capital

Accountancy Capital

The finance team behind them

Qualified finance professionals below director level who run reporting, client money and controls at regulated firms.

Visit Accountancy Capital

Which firm for which role?

The firms share one network and one database of around 10,000 candidates, so a regulated firm can come to whichever brand fits the role and still reach the whole group. As a rule of thumb:

  • Any senior manager function, or several at once: start with SMF Capital, particularly for authorisation team builds, combined SMF16 and SMF17 roles and urgent replacements.
  • Finance leadership and SMF2: FD Capital recruits regulated CFOs and finance directors, and fractional compliance officers and MLROs.
  • Chief executives and executive directors: Exec Capital handles SMF1, SMF3 and other executive senior managers.
  • Chairs, independent NEDs and committee chairs: NED Capital covers SMF9 to SMF14 and wider board appointments.
  • The finance team behind the senior managers: Accountancy Capital recruits financial controllers, CASS accountants and regulatory reporting specialists.

Our SMF recruitment guide works through each function in turn and points to the specialist page for every one.

The appointment timetable

How a senior manager appointment runs

Every SMF appointment follows the same broad path, whether it is a permanent hire, an interim or a fractional arrangement. Planning each stage from the start is the best way to avoid a gap in a required function.

The FCA’s 2026 reforms to the regime, set out in policy statement PS26/6, changed some of the timings. Firms now have 12 weeks to submit an application for a replacement senior manager, and the person providing cover can continue while that application is decided. Regulatory references must be provided within four weeks rather than six. The statutory deadline for the FCA to decide a complete application remains three months.

You can check who currently holds each function at any authorised firm on the Financial Services Register, which is also the first place a good recruiter checks a candidate’s history.

Define the role

Confirm the designated function, any prescribed responsibilities and a realistic time commitment for the firm’s size and risk.

Search and select

Target candidates whose experience matches the function and the sector, not just the job title.

Check fitness and propriety

Regulatory references, criminal records and credit checks, and a candid look at anything the FCA may ask about.

Apply for approval

Submit a complete application with a clear statement of responsibilities, and prepare the candidate for any interview.

Onboard and hand over

A proper handover pack and an updated responsibilities map, so accountability is clear from day one.

Topics we cover

The regulatory change driving senior hiring

Most senior manager vacancies are created by change: a new permission, a new regime, a supervisory letter or a firm crossing a threshold. These are the areas we follow most closely.

SMCR reform

The 12-week rule, faster regulatory references, raised Enhanced thresholds and new rules on non-financial misconduct. All change how firms plan and replace senior managers. See the FCA’s SMCR pages and our digest of recent changes.

Financial crime

MLROs carry personal accountability for anti-money laundering systems under the Money Laundering Regulations 2017, alongside sanctions screening overseen by OFSI. Demand for experienced MLROs, permanent and fractional, remains high.

Cryptoasset authorisation

The FCA’s authorisation gateway for the new cryptoasset regime opened on 30 September 2026, ahead of the regime taking effect on 25 October 2027. Applicants need credible senior managers, especially for compliance oversight and money laundering reporting.

Payments and e-money

The supplementary safeguarding rules that came into force in May 2026 brought daily reconciliations, a monthly safeguarding return and annual audits, raising the bar for finance and compliance leadership at payment and e-money firms.

Consumer credit and BNPL

The FCA began regulating Buy Now Pay Later on 15 July 2026. Lenders moving from temporary permissions to full authorisation need approved senior managers in place.

Dual-regulated firms

Banks, building societies and insurers answer to the Prudential Regulation Authority as well as the FCA, with additional functions such as SMF20 and SMF23 and a closer look at the collective suitability of the board.

About our founder

Adrian Lawrence FCA

Regulatory Capital and SMF Capital are part of The Capital Recruitment Group, founded by Adrian Lawrence. Adrian is a Fellow of the ICAEW who holds a practising certificate, a former listed-company Finance Director, and has led senior regulated appointments since founding FD Capital in 2018. He also hosts the SMF Unlocked podcast.

Adrian is a Chartered Accountant and every SMF Capital search is led by him personally, from the first conversation about the role through to FCA approval. View Adrian’s ICAEW profile.

Questions

Frequently asked questions

What is Regulatory Capital?

Regulatory Capital is a news and guidance site for FCA-regulated firms. It is published by the team behind SMF Capital and The Capital Recruitment Group, and covers regulatory change alongside the practical question of who firms need to hire to meet it.

Which senior manager functions does SMF Capital recruit for?

All of them, from SMF1 Chief Executive and SMF2 Chief Finance to the governance functions held by chairs and committee chairs, and the required SMF16 and SMF17 functions. It also recruits RDR-qualified senior managers and certified advisers. The SMF designations guide explains each function.

Can a senior manager be appointed on a fractional basis?

Yes, particularly at smaller firms. Fractional compliance officers and MLROs holding SMF16 and SMF17 are now common, provided the time commitment and support are proportionate to the firm’s size and risk. See fractional and interim SMF cover and our article on why more regulated firms are going fractional.

What happens if our MLRO or Compliance Officer resigns suddenly?

Under the reformed 12-week rule, a cover individual can step in while you submit an application for a permanent replacement, and can continue until the FCA decides it. SMF Capital’s urgent SMF replacement service covers both the interim and the permanent search.

We are applying for FCA authorisation. Who do we need?

It depends on your permissions and whether you will be a Limited Scope, Core or Enhanced firm, but most applicants need a chief executive, a compliance oversight holder and an MLRO in place, and often a finance lead. SMF Capital’s authorisation support page sets out the team the FCA expects to see.

Need a senior manager the FCA will approve?

Tell SMF Capital about the role, whether permanent, interim or fractional, and we will come back to you with how we would run the search, realistic timings and what the market is paying.