SMCR Compliance Recruitment
FD Capital is a specialist recruitment firm placing senior finance and compliance professionals in FCA-regulated organisations. We work with banks, insurers, payment institutions, wealth managers, fintechs and other supervised firms to provide the talent they need to meet their obligations under the Senior Managers and Certification Regime — whether that means a fractional CFO available two days a week, an interim MLRO at short notice, or a permanent Chief Risk Officer who can take on SMF4 accountability from day one.
SMCR compliance is not a one-off project. It is an ongoing governance obligation that requires firms to maintain appropriately qualified, FCA-registered individuals in their senior management functions at all times. When those individuals are unavailable, leave, or need supplementing, FD Capital has the network to step in quickly.
What is SMCR? A Brief Overview for FCA-Regulated Firms
The Senior Managers and Certification Regime (SMCR) is the FCA’s framework for individual accountability at regulated firms. It came into force for banks and major financial institutions in 2016 and was extended to all FCA solo-regulated firms in December 2019. SMCR replaced the previous Approved Persons Regime (APR) with a more granular, accountability-led structure.
SMCR has three components:
1. The Senior Managers Regime
Senior Managers are individuals holding a designated Senior Management Function (SMF). Each SMF carries a specific set of prescribed responsibilities — defined areas of the firm’s business for which that individual is formally accountable to the FCA. Senior Managers must be pre-approved by the FCA before taking up their role and must have a clear Statement of Responsibilities on file. Under the Duty of Responsibility, a Senior Manager can be held personally liable if a regulatory breach occurs in their area and they failed to take reasonable steps to prevent it.
The most relevant SMFs for FD Capital’s clients are SMF2 (Chief Finance Function), SMF3 (Executive Director), SMF4 (Chief Risk Function), SMF16 (Compliance Oversight) and SMF17 (Money Laundering Reporting Officer). FD Capital recruits for all five.
2. The Certification Regime
The Certification Regime covers a broader group of individuals in significant harm functions — those whose roles could cause significant harm to customers or the firm, but who are not Senior Managers. Firms must certify these individuals as fit and proper annually. Certification is the firm’s own responsibility; the FCA does not pre-approve certified persons. The regime typically covers senior analysts, traders, portfolio managers, and supervisors of certified functions.
3. Conduct Rules
The Conduct Rules apply to almost all employees of FCA-regulated firms (with limited exceptions). They set baseline standards of behaviour — acting with integrity, due care and skill, and cooperating with regulators. Firms must train all in-scope staff on the Conduct Rules and report breaches to the FCA within specific timeframes. Senior Managers and Certified Persons are subject to additional, more demanding Conduct Rules.
Key Senior Management Functions — What FD Capital Recruits
The table below sets out the SMFs most relevant to FD Capital’s practice and how we can help regulated firms fill each one on a permanent, interim or fractional basis.
| SMF | Role | Typical Title | FD Capital Can Place |
| SMF1 | Chief Executive Function | CEO | Via Exec Capital |
| SMF2 | Chief Finance Function | CFO / Finance Director | ✓ Permanent, interim, fractional |
| SMF3 | Executive Director | Executive Director (finance/risk) | ✓ Permanent, interim, fractional |
| SMF4 | Chief Risk Function | Chief Risk Officer / Head of Risk | ✓ Permanent, interim, fractional |
| SMF16 | Compliance Oversight | Head of Compliance / CCO | ✓ Permanent, interim, fractional |
| SMF17 | Money Laundering Reporting Officer | MLRO | ✓ Permanent, interim, fractional |
| SMF24 | Chief Operations Function | COO | Via Exec Capital |
Note: SMF1 (CEO) and SMF24 (COO) are placed by our sister business Exec Capital, which specialises in C-suite appointments across the full executive function.
How FD Capital Helps FCA Firms with SMCR Talent
The most common challenge FD Capital encounters is not firms building their SMCR structure from scratch — it is firms that need to maintain a compliant senior management team in the face of departure, growth, regulatory change, or cost pressure. SMCR creates a specific urgency: a Senior Manager vacancy is not simply a gap in the org chart, it is a potential regulatory exposure.
FD Capital addresses this through three models of engagement:
Fractional Senior Managers
A fractional appointment gives a regulated firm access to an experienced SMF holder for a defined number of days per week — typically two or three — on an ongoing retained basis. This is particularly suited to:
- Smaller FCA-regulated firms that cannot justify a full-time SMF2 (CFO) or SMF4 (CRO) but must have one in post
- Firms where the existing SMF holder is stretched across multiple functions and needs specialist support
- Growing fintechs and payment institutions that are scaling their regulatory infrastructure ahead of a supervisory visit
- Firms recovering from a sudden departure who need interim cover while a permanent search is underway
FD Capital currently has active fractional CFOs and Finance Directors available at two days per week, and fractional CROs at two to three days per week. These are senior professionals with FCA-regulated firm experience, familiar with SMCR accountability, Statements of Responsibilities and the FCA’s supervisory expectations. They can be in post within days of an engagement being agreed.
Interim Senior Managers
For urgent full-time requirements — a sudden MLRO departure, a s166 review requiring dedicated compliance leadership, or a regulatory remediation programme — FD Capital can provide experienced interim Senior Managers at short notice. Our interim network includes CFOs, FDs, MLROs and Heads of Compliance with track records in FCA-supervised environments. Typical interim placements run from three months to eighteen months depending on the assignment.
Permanent SMF Appointments
Where firms are looking to make a long-term hire into an SMF role, FD Capital conducts retained and contingency search. For senior SMF appointments, we recommend a retained mandate to ensure the depth of market coverage and candidate assessment that these roles require. Our approach includes structured competency assessment against the FCA’s Conduct Rules and a review of the candidate’s prior Statements of Responsibilities.
SMCR Senior Management Appointment — Day Rates and Salaries (UK, 2025)
The costs below reflect current market rates for experienced SMF holders in UK-regulated financial services. Fractional day rates typically carry a small premium over interim rates to reflect the dedicated availability and regulatory accountability involved.
| Role | SMF | Engagement Model | Typical Day Rate / Salary | Days/Week |
| Fractional CFO / FD | SMF2/3 | Fractional | £700 – £1,200/day | 2–3 days/week |
| Interim CFO / FD | SMF2/3 | Interim | £700 – £1,400/day | Full-time |
| Permanent CFO / FD | SMF2/3 | Permanent | £90,000 – £180,000 | Full-time |
| Fractional CRO | SMF4 | Fractional | £800 – £1,300/day | 2–3 days/week |
| Interim CRO | SMF4 | Interim | £800 – £1,400/day | Full-time |
| MLRO | SMF17 | Fractional / Permanent | £600 – £1,100/day | £90k–£150k | Flexible |
| Head of Compliance | SMF16 | Fractional / Permanent | £600 – £1,000/day | £75k–£130k | Flexible |
Fractional arrangements are typically structured as retained engagements with a fixed day commitment per week, invoiced monthly. Interim arrangements are time-and-materials based. FD Capital can advise on the most appropriate commercial structure for each situation.
SMCR Compliance Obligations That Drive Hiring Decisions
Understanding why firms come to FD Capital for SMCR-related talent requires understanding the regulatory pressure points that trigger hiring decisions. The most common are:
Senior Manager Departure
When an SMF holder leaves a regulated firm, the firm must notify the FCA promptly and ensure the function is covered. Leaving an SMF vacancy unfilled — particularly SMF2, SMF4, SMF16 or SMF17 — is a regulatory exposure. Firms routinely contact FD Capital when an SMF holder gives notice, needing interim cover while a permanent search is conducted. In some cases, firms appoint a fractional SMF holder to provide continuity throughout the permanent search, which can take three to six months for senior roles.
FCA Supervisory Visit or s166 Review
A Section 166 skilled person review or a proactive FCA supervisory engagement frequently reveals gaps in a firm’s SMCR arrangements — unclear Statements of Responsibilities, overlapping accountability, or functions operating without adequate senior oversight. Firms responding to FCA scrutiny often need to make rapid appointments to demonstrate credible governance. FD Capital has experience providing fractional and interim SMF holders in exactly these circumstances.
Consumer Duty Implementation
The FCA’s Consumer Duty (in force since July 2023) added a further layer of senior accountability for firms serving retail clients. The Consumer Duty champion — typically a Non-Executive Director with specific accountability for Consumer Duty outcomes — and the responsible SMF2 or SMF16 must be able to demonstrate that the firm has embedded the Duty across its products and services. Firms that have not yet done this work, or that need additional senior resource to complete it, represent a significant part of FD Capital’s current pipeline.
Authorisation and Variation of Permissions
Firms applying for FCA authorisation must demonstrate that their proposed Senior Managers are fit and proper, appropriately experienced and able to carry out their designated SMF responsibilities. FD Capital supports pre-authorisation firms in identifying and securing the right candidates for SMF2 (finance), SMF4 (risk) and SMF17 (MLRO) as part of their authorisation preparation. We also assist authorised firms undergoing a Variation of Permissions where additional senior oversight is required.
SMCR Recruitment Across Regulated Sectors
FD Capital’s SMCR recruitment practice spans the full range of FCA-regulated sectors. Each presents slightly different SMF requirements and talent pools:
- Payment institutions and e-money firms — high demand for SMF2 (fractional CFO) and SMF17 (MLRO); often fast-growing with lean headcount
- Retail and challenger banks — full SMCR applies; all five core SMFs required with clear accountability mapping
- Wealth managers and discretionary fund managers — SMF2 and SMF16 are the most frequently placed; conduct and Consumer Duty obligations are central
- Insurance intermediaries and MGAs — SMF2 and SMF17 most common; Lloyd’s market has additional considerations
- Fintechs seeking or holding FCA authorisation — typically need fractional SMF holders during growth phase before headcount justifies full-time SMF appointments
- Credit firms and consumer lenders — SMF16 and SMF2 in high demand given Consumer Duty obligations and FCA focus on fair value
SMCR Recruitment — Frequently Asked Questions
Does a fractional CFO count as an SMF2 holder under SMCR?
Yes, in most cases. The FCA’s rules do not require an SMF holder to be a full-time employee. What matters is that the individual is clearly identified as accountable for the relevant function, has a current Statement of Responsibilities, and is registered with the FCA. Fractional arrangements must be carefully structured so that the accountability is unambiguous and the SMF holder has sufficient time and information to discharge their responsibilities properly. FD Capital’s fractional SMF candidates are experienced in operating under SMCR and can advise on how to structure their appointment correctly.
How quickly can FD Capital provide an interim SMF17 (MLRO)?
For interim MLRO appointments, FD Capital can typically present a shortlist of qualified candidates within 48 to 72 hours. Availability depends on the specific firm type and sector — MLRO candidates with payment institution experience are in particularly high demand — but our active network significantly reduces time-to-placement. For fractional MLRO arrangements, we can often make introductions within 24 hours.
What is the difference between SMF16 and SMF17?
SMF16 is the Compliance Oversight function, held by the individual responsible for the firm’s overall compliance framework — typically the Head of Compliance or Chief Compliance Officer. SMF17 is the Money Laundering Reporting Officer, the individual with specific statutory responsibility for the firm’s anti-money laundering controls and suspicious activity reporting under POCA 2002 and the Terrorism Act 2000. In smaller firms these functions are often held by the same person. In larger organisations they are typically separate appointments. FD Capital recruits for both — see our MLRO Recruitment and Compliance Recruitment pages for more detail.
What does a Statement of Responsibilities contain?
A Statement of Responsibilities (SoR) is the document that sets out the areas of the firm’s activities for which a Senior Manager is personally responsible and accountable. It must be agreed between the firm and the Senior Manager, kept up to date as responsibilities change, and submitted to the FCA at the point of SMF application. The SoR is a live document — it should be reviewed whenever the firm’s structure changes or the Senior Manager’s role evolves. FD Capital’s candidates for SMF roles will typically have prior Statements of Responsibilities from previous appointments, which provides evidence of their practical experience of operating under the regime.
Can the same person hold multiple SMFs?
Yes, subject to the FCA’s rules on SMF combinations. The FCA permits smaller firms to combine certain SMFs in a single individual — for example, SMF2 and SMF3 can be held by the same person in a simplified firm, and SMF16 and SMF17 are commonly combined in smaller regulated businesses. The FCA prohibits certain combinations for prudential reasons — most notably, the same individual cannot hold both the CEO function (SMF1) and certain oversight functions simultaneously. FD Capital can advise on permissible combinations when structuring fractional or interim appointments.
Does SMCR apply to overseas firms with a UK branch?
Yes. Overseas firms with a UK branch authorised by the FCA are subject to SMCR in respect of their UK-regulated activities. The regime applies to the individuals performing Senior Management Functions for the UK branch, even if they are employed by the overseas parent. Firms in this position sometimes use fractional SMF holders based in the UK to provide local SMCR accountability without building a full UK management team. FD Capital has placed fractional SMF holders for exactly this purpose.
Discuss Your SMCR Resourcing Requirements
Whether you need a fractional CFO to hold SMF2 accountability for two days a week, an interim MLRO at short notice, or a permanent CRO for a growing regulated business, FD Capital has the candidates and the expertise to help.
We understand the regulatory constraints that SMCR creates — the need for FCA registration, the Statement of Responsibilities, the accountability mapping — and our candidates understand them too. This means we can move quickly without compromising on the regulatory quality of the appointment.
Call us to discuss your requirements or submit a brief via our website. For urgent interim and fractional requirements, we can typically make initial introductions on the same day.
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