SMF Capital

Adrian
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About SMF Unlocked SMF Unlocked is the podcast for anyone recruiting, holding, or thinking about taking on an FCA Senior Manager Function. Every episode unpacks a specific part of the Senior Managers and Certification Regime — what a designation like Chair, Chief Risk Officer, Compliance Oversight or MLRO actually requires, how the fit and proper test works in practice, and where boards and firms most often get SMF appointments wrong before it's too late to fix cheaply. This isn't a regulatory affairs show for compliance academics. It's a practical, direct look at SMF appointments from someone who runs these searches for a living — real patterns from real searches, the questions that actually separate a strong candidate from a risky one, and the mistakes that turn a straightforward appointment into a six-month Form A headache. About the host Adrian Lawrence FCA is a Fellow of the ICAEW and founder of SMF Capital, a UK recruitment practice specialising in FCA Senior Manager Function appointments — executive and non-executive. He founded FD Capital in 2018 and has since built out Exec Capital, NED Capital and Accountancy Capital alongside SMF Capital, working with boards, investors and regulated firms across the UK on senior and board-level appointments. He leads every SMF search personally, which is where most of what ends up in this podcast actually comes from. Who this is for Board members and non-executive directors navigating a Chair or committee chair appointment. Compliance and financial crime professionals building a case for their next SMF16 or SMF17 role. HR and governance teams trying to work out which designation actually applies to a role they're hiring for. And anyone who's been through an SMF appointment that went sideways and wants to understand why. New episodes regularly. Subscribe wherever you listen, and find detailed written guides to every SMF designation at smfcapital.co.uk.

Episodes

  1. 4h ago

    SMF1: What It Takes to Be Approved as a Regulated CEO

    Let's take a closer look at one of the most important senior management functions: SMF1, the Chief Executive function. For many businesses seeking FCA authorisation, the CEO is going to be central to the proposed governance structure. But becoming the CEO of a regulated business is different from simply becoming the CEO of an ordinary commercial company. An SMF1 holder has a specific senior management responsibility within the regulated firm, and the individual needs to be approved to perform that function where the regulatory regime requires it. So what does the regulator want to see? Again, it's not simply about having an impressive job title. The individual's previous experience, competence, responsibilities and understanding of the regulated environment all become relevant. A successful commercial entrepreneur, for example, may have excellent experience building a business, but that doesn't automatically mean they have the regulatory experience required for a particular SMF1 role. Equally, someone who has spent years in a regulated financial services environment may have extensive regulatory knowledge but a different type of leadership experience. The important question is whether the individual's overall experience is appropriate for the role they are being proposed for. We've put together a dedicated guide explaining SMF1: What It Takes to Be Approved as a Regulated CEO. It's particularly useful for founders and senior executives who are moving from an unregulated business environment into a regulated financial services business. And SMF1 is only one part of the wider framework. There are a number of different SMF designations covered by the FCA regime, with the appropriate requirements depending on the type of firm, its activities and its governance structure. That's why SMF planning shouldn't start with individual job titles. It should start with the proposed regulated business. What permissions are being sought? What activities will the firm undertake? What governance structure is being proposed? Which senior management functions apply? And who has the appropriate experience to take responsibility for each of them? Once those questions have been answered, the recruitment process becomes much more targeted. And for a new regulated business, getting that structure right at the beginning can be considerably more straightforward than trying to redesign it shortly before an FCA application is submitted.

  2. 4h ago

    The Fit and Proper Test: What the Regulator Is Really Asking

    There's another important part of the authorisation process that shouldn't be overlooked: the Fit and Proper Test. Identifying somebody for an SMF position is only part of the process. The regulator also needs to consider whether the individual is fit and proper to perform the role. So what does that actually mean? At a practical level, the assessment considers whether the individual has the appropriate honesty, integrity and reputation, competence and capability, and financial soundness, as applicable to the relevant regulatory requirements. That means the recruitment process shouldn't simply ask: "Does this person have the right job title on their CV?" It should ask: "Can this individual demonstrate the experience, competence and personal suitability required for the role they're being proposed for?" This is particularly important when you're building an SMF team for a new regulated business. A candidate might have extensive experience in financial services, but that doesn't automatically mean they are the right person for every SMF role. Their previous responsibilities, regulatory experience, technical knowledge and the relevance of their background all need to be considered in the context of the proposed position. We've produced a detailed guide explaining the Fit and Proper Test and what it means for regulatory approval. It's worth understanding this before starting the recruitment process, because it changes the question from simply finding a senior executive to finding someone who is appropriate for a specific regulated responsibility. Recruitment and Regulatory Approval This is where the connection between recruitment and authorisation becomes particularly important. If you're recruiting an SMF16, SMF17, chair or another senior regulated individual, you're not simply filling a vacancy. You're potentially identifying an individual whose appointment forms part of your regulatory application and governance structure. That means the recruitment process needs to consider the regulatory requirements from the beginning. At SMF Capital, our SMF Recruitment Services are designed to help firms identify senior financial services professionals for regulated and senior management positions. The objective is to combine the recruitment requirement with an understanding of the regulatory environment in which the individual will operate. So rather than starting with a generic job description and then looking for candidates, the process can start with the firm's regulatory requirements, governance structure and the responsibilities attached to the role. That can help create a much more focused search for the right senior individual.

  3. 2d ago

    SMF Authorisation Support: Building the Right Senior Management Team Before FCA Submission

    Welcome to the SMF Capital Podcast. Today we're looking at an issue that can make a significant difference to the FCA authorisation process: when and how you build your Senior Management Function team. If you're a fintech, payments business, cryptoasset firm or another business preparing for FCA authorisation, it's tempting to concentrate first on the business plan, technology, commercial proposition and customer proposition — and then deal with the senior management structure towards the end. But that can create a problem. Because FCA authorisation isn't simply about whether your business model looks good on paper. The FCA also needs to understand who is actually going to run the regulated business, who is responsible for key functions, and whether those individuals have the appropriate experience and accountability. That's where SMF Capital's authorisation support comes in. Why SMF planning needs to start early One of the biggest mistakes we see is treating SMF recruitment as something that happens immediately before an application is submitted. In reality, the senior management structure should be considered much earlier. You need to understand which SMF designations apply to your particular firm, which individuals will take responsibility for key functions, how those responsibilities fit together and whether the proposed structure is proportionate to the firm's activities and regulatory permissions. For many firms, this will include functions such as SMF16 — Compliance Oversight and SMF17 — Money Laundering Reporting Officer, depending on the firm's regulatory structure and activities. And for businesses operating in areas such as payments, e-money or cryptoassets, the quality and relevance of that experience can be particularly important. The question isn't simply: "Can we find somebody with an SMF16 or SMF17 title?" The more important question is: "Does this person have the right experience for our particular business, risk profile and regulatory environment?" That's a very different recruitment exercise. The importance of sequencing Let's take a typical example. Imagine you're building a fintech business and you've already recruited your commercial leadership team. You've got the technology team. You've developed your product. You've prepared your business plan. You're getting closer to submitting your FCA application. Then somebody asks: "Who is our SMF16?" And: "Who is our SMF17?" If the answer is that you're going to start looking for those people now, you may have left an important part of the process rather late. Instead, the better approach is to work backwards from the intended authorisation timetable. What is the target submission date? Which SMF roles are required? Which individuals need to be identified? Which people need to be permanent appointments? Where could fractional or interim expertise provide appropriate cover? And how should the responsibilities of those individuals be reflected in the governance documentation? That sequencing is one of the key areas where specialist SMF recruitment support can add value. Finding the right SMF16 Let's start with Compliance Oversight. An SMF16 isn't simply a compliance job with a more senior title. The individual needs to be appropriate for the firm's business model and regulatory permissions. For example, the compliance requirements and risks associated with a payments business can be very different from those of another type of regulated firm. So the recruitment process needs to look at the individual's actual experience. Have they worked in a comparable regulated environment? Have they dealt with the types of regulatory permissions you're applying for? Do they understand the risks inherent in your business model? And can they operate effectively within the governance structure you're proposing? These are much more useful questions than simply searching a database for somebody whose CV contains the words "SMF16". Finding the right SMF17 The same principle applies to the Money Laundering Reporting Officer. For businesses with significant financial crime exposure, particularly payments, e-money and cryptoasset businesses, experience needs to be relevant to the firm's actual risk environment. A generic AML background isn't necessarily the same thing as experience managing financial crime risk within a comparable regulated business. The objective should therefore be to identify an SMF17 candidate whose experience makes sense in the context of the application you're putting in front of the FCA. Again, it's about fit rather than simply filling a box. What about the board? The SMF structure doesn't exist in isolation. Depending on the firm's size, activities and regulatory requirements, the wider board and governance structure may also need careful consideration. That can include the chair, independent non-executive directors and other senior appointments. This is particularly important where the business is moving from an entrepreneurial start-up structure towards a properly governed regulated firm. The question becomes: Does the proposed board structure demonstrate that the firm understands the responsibilities that come with being regulated? And if an experienced board-level appointment is required, that appointment may need to happen well before the authorisation submission rather than being left until after authorisation. Statements of Responsibilities Another area that deserves attention is the Statement of Responsibilities. These shouldn't simply be treated as documents that need to be completed because the application form requires them. They should reflect the actual governance structure of the business. Who is responsible for what? Where do responsibilities begin and end? How do the different SMF roles interact? Who has oversight? And does the overall structure make sense? A generic template can produce a document that technically looks complete but doesn't necessarily demonstrate that the firm's governance has been properly thought through. The documentation should reflect the organisation you're actually building. Do you need full-time SMFs immediately? Not necessarily. This is another area where the recruitment model has changed considerably. For some firms, a fractional or interim SMF16 or SMF17 can make sense during the authorisation process and the early months of trading. It can provide specialist expertise while the business is still developing its operational scale. Then, as the firm grows, the role can transition to a permanent full-time appointment when the volume and complexity of the business justify it. The important point is that the individual should have genuine experience of the authorisation environment. There is a difference between somebody who has spent years running an established compliance function and somebody who understands what it takes to help build that function as part of an FCA authorisation process. Working backwards from your submission date So if you're currently preparing for FCA authorisation, here's a useful exercise. Take your intended submission date. Work backwards. Identify the SMF designations your firm is likely to require. Determine which individuals need to be appointed or identified. Assess whether those individuals have genuinely relevant experience. Consider whether any roles should initially be fractional or interim. Then make sure the governance structure and Statements of Responsibilities reflect the organisation you're actually proposing. This turns SMF recruitment from a last-minute exercise into part of the authorisation strategy. How SMF Capital can help That's precisely where SMF Capital's SMF Authorisation Support service is designed to help. We work with firms preparing for authorisation — particularly in fintech, payments and cryptoassets — to identify and build the senior management structure required ahead of submission. That can include: Identifying appropriate SMF16 candidatesIdentifying SMF17 and MLRO candidatesReviewing the wider board and chair requirementsHelping structure Statements of ResponsibilitiesIdentifying fractional and interim SMF solutionsPlanning the recruitment sequence around the FCA submission timetableThe approach starts with the business model and the intended authorisation timeline. Then we work backwards. The objective isn't simply to fill individual vacancies. It's to build a credible senior management structure that makes sense for the regulated business you're trying to create. Closing If you're preparing an FCA authorisation application and you're wondering when you should start building your SMF team, the answer is: earlier than many businesses think. You can find out more about SMF Capital's SMF Authorisation Support service at: https://www.smfcapital.co.uk/smf-authorisation-support/ And if you already have a target FCA submission date, SMF Capital can work backwards from that date to help determine the senior management recruitment sequence. That's all for this episode of the SMF Capital Podcast. Thanks for listening.

  4. 2d ago

    Understanding FCA-Regulated Financial Advice — What Business Owners and Investors Need to Know

    Welcome to today’s episode, where we’re looking at an important subject for anyone dealing with investments, financial planning or regulated financial services: what does FCA regulation actually mean, and why does it matter? The financial services industry uses a lot of terminology — FCA authorised, FCA regulated, appointed representative, financial adviser, investment advice and financial promotion. But what do these terms actually mean? And perhaps more importantly, how can individuals and business owners make sure they are dealing with the right type of financial professional? Today, we’ll explore those questions and introduce SMF Capital, a specialist financial services business that can help clients navigate this area. What is the FCA? Let’s start with the FCA. The Financial Conduct Authority, commonly known as the FCA, is the UK regulator responsible for regulating financial markets and financial services firms. Its role includes regulating the conduct of firms and helping ensure that financial markets operate with appropriate standards of integrity and consumer protection. This is particularly important because financial products and services can involve significant sums of money and, in some circumstances, significant investment risk. Being able to establish whether a firm or individual is appropriately authorised is therefore an important part of choosing a financial services provider. What does "FCA regulated" actually mean? You will often hear businesses describe themselves as "FCA regulated". However, it is worth being precise about the terminology. A firm may be authorised and regulated by the FCA, while individuals working within financial services may have different regulatory statuses depending on their role and the activities they undertake. There are also businesses that operate as appointed representatives of authorised firms. So rather than relying simply on a phrase appearing on a website, clients should consider checking the firm's regulatory status and understanding what regulated activities it is authorised to undertake. That distinction matters. FCA regulation isn't simply a marketing badge. It relates to the activities a firm is permitted to conduct and the regulatory framework within which it operates. Why does this matter to clients? For a client, understanding the regulatory position of a financial services business can provide an important starting point when assessing who they are dealing with. It can also help clients ask better questions. For example: Is the firm authorised by the FCA?What activities is it authorised to undertake?Who will actually provide the advice?Is the service regulated?What fees will be charged?What risks are involved?What happens if something goes wrong?What protections or complaints procedures apply?These are sensible questions whenever you are considering a financial service. Financial advice versus financial information Another important distinction is between financial information and regulated financial advice. There is a huge amount of financial information available online. You can read about pensions, investments, ISAs, tax planning, markets and financial products within seconds. But information isn't necessarily personalised advice. Financial advice considers an individual's or business's circumstances, objectives, risk tolerance and other relevant factors. That distinction is particularly important when dealing with investments or other regulated financial products. Why specialist expertise matters Financial services can become complicated very quickly. A business owner might be thinking about investments, retirement planning, company finances or longer-term wealth management. An individual may be considering pensions, investments or how to structure their financial affairs. In each case, the appropriate solution depends on the circumstances. That is why working with experienced professionals and understanding exactly what service is being provided is so important. Introducing SMF Capital This brings us to SMF Capital. SMF Capital provides a specialist financial services proposition designed to help clients navigate the increasingly complex financial landscape. If you're looking for more information about SMF Capital, its services and the firm's approach, visit: https://www.smfcapital.co.uk/ The website provides further information and is the best place to start when you want to understand what SMF Capital does and how it can assist clients. The importance of doing your own research One final point is worth emphasising. Whether you're choosing a financial adviser, investment professional or another financial services provider, don't be afraid to do your research. Check the firm's regulatory status where appropriate. Understand what services are actually being offered. Ask about fees. Ask about risk. And make sure you understand whether you are receiving regulated financial advice or simply general information. Good financial decisions generally start with good information. Closing So, to recap: The FCA plays an important role in regulating financial services in the UK. Understanding the difference between FCA authorisation, regulated activities and general financial information can help clients make more informed decisions. And if you're looking for further information about specialist financial services, take a look at SMF Capital at: https://www.smfcapital.co.uk/ That's all for today's episode. Thanks for listening, and we'll be back soon with another discussion about the UK financial services industry, financial advice and the issues affecting businesses and investors today.

  • 4 Episodes

About

About SMF Unlocked SMF Unlocked is the podcast for anyone recruiting, holding, or thinking about taking on an FCA Senior Manager Function. Every episode unpacks a specific part of the Senior Managers and Certification Regime — what a designation like Chair, Chief Risk Officer, Compliance Oversight or MLRO actually requires, how the fit and proper test works in practice, and where boards and firms most often get SMF appointments wrong before it's too late to fix cheaply. This isn't a regulatory affairs show for compliance academics. It's a practical, direct look at SMF appointments from someone who runs these searches for a living — real patterns from real searches, the questions that actually separate a strong candidate from a risky one, and the mistakes that turn a straightforward appointment into a six-month Form A headache. About the host Adrian Lawrence FCA is a Fellow of the ICAEW and founder of SMF Capital, a UK recruitment practice specialising in FCA Senior Manager Function appointments — executive and non-executive. He founded FD Capital in 2018 and has since built out Exec Capital, NED Capital and Accountancy Capital alongside SMF Capital, working with boards, investors and regulated firms across the UK on senior and board-level appointments. He leads every SMF search personally, which is where most of what ends up in this podcast actually comes from. Who this is for Board members and non-executive directors navigating a Chair or committee chair appointment. Compliance and financial crime professionals building a case for their next SMF16 or SMF17 role. HR and governance teams trying to work out which designation actually applies to a role they're hiring for. And anyone who's been through an SMF appointment that went sideways and wants to understand why. New episodes regularly. Subscribe wherever you listen, and find detailed written guides to every SMF designation at smfcapital.co.uk.

Information

  • Creator
    Adrian
  • Years Active
    2026
  • Episodes
    4
  • Rating
    Clean
  • Copyright
    © 2026 SMF Capital
  • Show Website
    SMF Capital