SMF Capital

Adrian Lawrence FCA, SMF Capital

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.

  1. 23h ago

    Four Specialist Recruitment Brands, One Senior Network

    Today we're looking at four specialist recruitment businesses that cover some of the most important senior, regulatory, finance and tax appointments facing UK businesses: SMF Capital, Regulatory Capital, Tax Capital and FD Capital Group. The four websites are: www.smfcapital.co.uk www.regulatorycapital.co.uk www.taxcapital.co.uk www.fdcapitalgroup.co.uk Together, they represent a specialist approach to recruitment: rather than trying to be everything to everyone, each business focuses on a particular area of expertise. SMF Capital Let's start with SMF Capital. SMF Capital specialises in Senior Management Function recruitment for FCA-regulated firms. That means recruiting people whose appointments can carry direct regulatory accountability. The business covers roles including SMF1 Chief Executive, SMF2 Chief Finance Function, SMF4 Chief Risk Officer, SMF5 Head of Internal Audit, SMF16 Compliance Officer, SMF17 MLRO and SMF24 Chief Operating Officer, together with chairs, committee chairs and other senior functions. What makes an SMF appointment different from conventional executive recruitment is that the regulator has a view on the appointment. The candidate needs to meet the relevant fit and proper requirements and be capable of carrying the responsibilities attached to the function. That means the recruitment process needs to consider regulatory suitability from the beginning rather than treating FCA approval as something that happens after the hiring decision. SMF Capital also provides fractional and interim SMF cover. That can be particularly valuable when a regulated firm suddenly loses a Compliance Officer or MLRO, needs temporary cover during an approval process, or is too small to require a full-time senior appointment. The business also supports firms going through authorisation, governance reviews, board restructuring and multi-SMF team builds. For FCA-regulated businesses, specialist knowledge can make a significant difference. Regulatory Capital The second specialist area is Regulatory Capital. Capital is fundamental to regulated financial services. A regulated business may need specialist knowledge of prudential requirements, capital calculations, liquidity, regulatory reporting, stress testing and the particular framework applicable to its business model. The requirements facing an investment firm are not necessarily the same as those facing a bank, insurer, payments business or other regulated organisation. That is why regulatory capital recruitment requires more than simply finding someone with a conventional finance background. The right candidate needs to understand the interaction between finance, regulation and the firm's business model. This can be particularly important when a business is growing, changing its regulatory permissions, preparing for authorisation or facing increasing prudential complexity. The finance professional may need to communicate with the board, regulators and other control functions while ensuring that commercial decisions remain consistent with the firm's capital position. Regulatory Capital is therefore focused on the specialist people who understand that environment. Tax Capital The third specialist business is Tax Capital. Tax is another area where technical expertise matters enormously. Modern businesses can face complex requirements involving corporation tax, international tax, VAT, indirect tax, transfer pricing, employment tax and other specialist areas. At senior level, a tax professional is not simply responsible for compliance. They may be involved in acquisitions, international expansion, group structuring, tax risk, strategic planning and discussions with the board. The difference between someone with general tax exposure and someone who genuinely specialises in the relevant discipline can therefore be substantial. Tax Capital focuses on connecting businesses with professionals who have the technical expertise required for their particular tax requirements. That could mean a senior Tax Director, corporate tax specialist, VAT professional, international tax expert or another specialist tax appointment. The principle is straightforward: the more complex the requirement, the more important genuine specialisation becomes. FD Capital Group The fourth website is www.fdcapitalgroup.co.uk. FD Capital Group provides the wider group structure behind a network of specialist recruitment businesses. The group originated with FD Capital, which was founded to recruit Finance Directors and CFOs on fractional, interim and permanent bases. It has subsequently developed a wider specialist network covering finance leadership, executive leadership, non-executive appointments, qualified finance professionals and FCA-regulated senior managers. The important point about the group model is that the specialist brands remain focused while sharing access to a wider senior candidate network. That means a client can approach the business for one requirement and, where appropriate, access expertise from another specialist area. For example, a growing company might need a CFO and Financial Controller. A regulated business might need an SMF2 CFO alongside an SMF16 Compliance Officer and SMF17 MLRO. A private-equity-backed company might require a CFO, CEO and independent Non-Executive Chair. These are different recruitment requirements, but they can exist within the same organisation. Why Specialisation Matters There is a common theme running through all four businesses. Senior recruitment is becoming increasingly specialised. A company does not simply need someone with a particular job title. It needs someone with the right technical background, sector experience and ability to operate within its particular environment. For an SMF appointment, that includes regulatory accountability. For a regulatory capital role, it includes prudential and capital expertise. For a tax appointment, it means understanding the relevant tax discipline. For a CFO or Finance Director, it can mean combining technical finance expertise with commercial leadership. This is why specialist recruitment can be more effective than a generic approach. The recruiter needs to understand the problem before trying to identify the person who can solve it. Permanent, Interim and Fractional Appointments Another common theme is flexibility. Not every business needs a permanent executive immediately. Sometimes a company needs an interim leader during a transaction, restructuring or period of rapid growth. Sometimes a smaller business needs a CFO, Compliance Officer or other senior specialist for only one or two days a week. And sometimes an urgent vacancy means that temporary cover is required while a permanent search is undertaken. Fractional and interim recruitment can therefore provide businesses with access to senior expertise without immediately committing to a full-time appointment. This can be particularly valuable for growing businesses and regulated firms. One Network, Specialist Expertise Ultimately, the idea behind these businesses is simple. Specialist recruitment does not mean operating in isolation. It means understanding a particular market deeply while still being able to draw on a wider network when a client's requirements cross disciplines. SMF Capital focuses on FCA Senior Management Functions. Regulatory Capital focuses on specialist regulatory and prudential finance expertise. Tax Capital focuses on specialist tax professionals. FD Capital Group provides the wider senior recruitment network and group structure connecting these specialist areas. For clients, that creates a useful combination: specialist knowledge when you need it, with access to a broader senior network when the requirement spans several disciplines. Final Thoughts Whether your business needs an SMF16 Compliance Officer, an MLRO, a regulatory CFO, a capital specialist, a Tax Director, a Finance Director or another senior professional, the starting point should be understanding exactly what the role requires. Technical expertise matters. Sector experience matters. Regulatory understanding matters. And at senior level, judgement matters just as much. That is the approach behind SMF Capital, Regulatory Capital, Tax Capital and FD Capital Group. Four specialist destinations, focused on different parts of the senior recruitment market

  2. 1d ago

    Compliance Monitoring Explained: What FCA-Regulated Firms Need to Know

    Today we're looking at one of the most important parts of an effective compliance function: compliance monitoring. For FCA-regulated firms, compliance monitoring is much more than a box-ticking exercise. It is the process of checking whether the business is actually complying with its regulatory obligations, following its own policies and procedures, operating effective controls and delivering the outcomes customers should receive. SMF Capital has produced a detailed guide to the subject: https://www.smfcapital.co.uk/compliance-monitoring-explained/ So, what does good compliance monitoring actually involve? It Starts With Risk The first principle is that monitoring should be risk based. A firm should not simply create a list of reviews at the beginning of the year and repeat exactly the same programme every year. The monitoring programme should reflect the firm's actual risks. That means considering its regulated activities, products, customer base and distribution channels, together with complaints, breaches, previous monitoring findings, audit results, regulatory developments and changes within the business. Higher-risk areas should generally receive more frequent and more detailed testing. This is important because compliance monitoring is not simply about checking whether a policy exists. A policy may say that customers must be assessed in a particular way. Monitoring needs to establish whether that process is actually followed, whether the controls work in practice and whether the resulting customer outcomes are appropriate. Consumer Duty Has Changed Monitoring The Consumer Duty has made this even more important for retail firms. It is no longer enough to demonstrate that a process was followed. Firms increasingly need evidence that customers are actually receiving good outcomes across products and services, price and value, consumer understanding and consumer support. That means compliance monitoring may need to examine customer data, complaints, cancellation rates, arrears, call handling and other outcome information. It also means considering whether vulnerable customers or particular customer groups are receiving worse outcomes. In other words, monitoring needs to look beyond paperwork and establish what is actually happening. The Three Lines Another important consideration is the relationship between the three lines of defence. The first line is the business itself. Advisers, operations teams, customer service and other employees own the risks and operate the day-to-day controls. The second line is compliance and risk. This function sets standards, provides advice and independently tests whether controls are operating effectively. The third line is internal audit, providing independent assurance over the overall framework. Smaller firms may not have the same level of separation between these functions. That can be perfectly reasonable if it is proportionate, but the firm needs to recognise any limitations on independence. For example, there is an important difference between someone designing a control and someone independently testing whether that control works. Building the Monitoring Programme A good programme normally begins by defining the firm's compliance universe. What

  3. Oct 18

    SMF Recruitment in London – Finding the Right Senior Managers in the UK’s Most Competitive Market

    Welcome to SMF Unlocked, the podcast for anyone recruiting, holding, or thinking about taking on an FCA Senior Manager Function. I’m Adrian Lawrence, founder of SMF Capital, and every search we run is led by me personally. Today we’re focusing on one place that dominates the UK Senior Manager market more than any other: London. If you’re hiring a Senior Manager in London – or you’re an approved person weighing up your next move in the city – this episode is for you. We’re going to look at why London is both the deepest and the most competitive pool of SMF talent in the country, how the different sectors behave, what actually works when you’re trying to secure the right person, and how we structure searches so the regulator’s fit and proper test is built in from the first conversation rather than bolted on at the end. You can find the full written guide and contact details at the page we’re discussing today: https://www.smfcapital.co.uk/smf-recruitment-london/ Let’s start with the market itself. London has the largest concentration of FCA and PRA-regulated firms in the UK and the deepest pool of approved Senior Managers. It is also the most competitive market for them. Banks, insurers, asset managers, market infrastructure firms, hedge funds, private equity, private wealth, payments, e-money and crypto-asset businesses all sit within a relatively small geographic area. The City and Canary Wharf house the bulk of the dual-regulated firms. Mayfair and St James’s remain the centre of gravity for much of the alternative investment and private wealth industry. Shoreditch, Old Street and King’s Cross continue to attract newer payment, e-money and crypto businesses. Both regulators are based here too – the FCA in Stratford and the PRA at the Bank of England. That density creates opportunity and friction at the same time. London firms have access to more experienced Senior Managers than anywhere else in the country, but they are also competing with each other for the best of them. An approved Chief Risk Officer with PRA experience, or an MLRO who has taken a payments firm through authorisation, will often have several live options. The firms that hire well are the ones that move with clarity and speed, make a coherent case for the role, and present candidates to the regulator without avoidable gaps in the application. Different parts of the London market have their own characteristics. Banks, building societies and other dual-regulated firms carry the widest set of Senior Manager Functions and Prescribed Responsibilities. Board appointments bring PRA scrutiny of collective suitability as well as individual fitness and propriety. When we run these searches we look carefully at how a candidate will fit the existing board, not just the individual role in isolation. Asset managers, hedge funds and private equity firms range from global houses to small MIFIDPRU firms with a handful of staff. For smaller firms the practical answer is often a combined SMF16 and SMF17 or a fractional Senior Manager arrangement. Larger firms approaching Enhanced status face a different challenge: building the risk and audit committee capability the regime expects. The difference between firm tiers matters, and we map the search to the actual regulatory expectations rather than a generic job title. Insurance and the Lloyd’s market form another distinct ecosystem. Managing agents, carriers and MGAs each need Senior Managers with genuine market experience. Dual-regulated insurers answer to both regulators, so the search has to reflect that dual scrutiny. Fintech, payments and crypto-asset firms generate a steady flow of first-time authorisation cases. Their initial Senior Manager appointments often determine whether an application succeeds. Founders need people the regulator can rely on – especially around safeguarding, financial crime and the FCA’s approach to newer business models. We spend a lot of time helping pre-authorisation firms assemble credible teams rather than simply filling vacancies at the last minute. Overseas firms opening UK branches almost always choose London. The SMF19 Head of Third Country Branch has to reassure the regulators about a business with no UK track record. That requires a particular combination of regulatory credibility and commercial judgement. In London the question is rarely whether suitable Senior Managers exist. It is whether you can identify and secure the right one before another firm does, and then present them cleanly to the regulator. That brings us to how we actually run an SMF search in London. The core method is the same wherever the firm is based, because the regulator’s test is the same. What changes by location is the candidate market, the competing employers and the pay expectations. Local knowledge matters. We start from the Statement of Responsibilities the new Senior Manager will sign and any Prescribed Responsibilities they will carry. The specification is built around those documents rather than around a conventional job title. We approach candidates directly and in confidence – most of the people we speak to are not actively looking. Before anyone reaches a shortlist we test them against what the approval application will ask: prior approvals, regulatory history, directorships and financial soundness, measured against the fit and proper test. We also start regulatory references early. A late reference remains one of the most common causes of delay in the process. I interview every shortlisted candidate personally. We stay involved until the individual is approved and in post. The full service covers permanent, interim and fractional appointments across board and executive roles, control functions, and firm structure work including team builds, tier changes, governance reviews and overseas firm support. A few practical realities of London hiring are worth spelling out. Pay is the highest in the UK. Packages at larger firms usually include variable remuneration subject to regulatory deferral and clawback. Smaller firms rarely win on base salary alone. They win on scope, equity, flexibility and the chance to build a function. We give clients an honest view of where their package sits before the search starts so offers do not fail at the final stage. Notice periods for Senior Managers in London commonly run three to six months. The regulator can take up to three months to decide a complete application. When these timelines are planned together they can run in parallel. When they are planned separately they can push a start date back by half a year. If a Senior Manager leaves unexpectedly, the 12-week rule allows temporary cover. Since the April 2026 reforms the firm must submit an application within that period if the person covering is to continue. We can provide interim cover and run the permanent search at the same time. The designations we see most frequently in London mandates are compliance oversight and MLRO roles, Chief Risk Officers, Chairs and independent committee chairs, and Chief Operations holders at firms focused on operational resilience. You can check any candidate’s current approvals on the FCA Financial Services Register before interview. Under the Senior Managers and Certification Regime each Senior Manager answers personally for their area. London candidates understand this well. The strongest ones ask hard questions about governance, resourcing and their predecessor’s departure before accepting. Firms that answer those questions openly tend to hire better. A few questions we hear regularly: Do we only recruit London-based Senior Managers for London firms? No. Many London firms now accept hybrid working, which widens the pool to candidates across the South East and beyond. We search wherever the right candidate is, within the attendance pattern the role needs. How quickly can we shortlist for a London SMF role? A typical shortlist takes three to five weeks, depending on the designation and how specialist the sector experience needs to be. Interim cover can often be arranged sooner. Can we help a London firm that has not yet been authorised? Yes. Pre-authorisation firms form a significant part of our London work. Do we recruit for PRA-designated Senior Manager roles? Yes. We work with dual-regulated banks and insurers where appointments need PRA as well as FCA approval. SMF Capital was founded by me, Adrian Lawrence FCA. I am a Chartered Accountant and Fellow of the ICAEW, a former listed-company Finance Director, and I lead every SMF search personally, including those for London firms. I interview every shortlisted candidate myself. If you are recruiting a Senior Manager in London, or you are an approved person considering a move into or within the city, the practical next step is straightforward. Tell us the designation, the firm type and your timing. We will come back to you the same working day, with the fit and proper assessment built into the search from the first conversation. The full page with more detail on London’s SMF market, sector nuances, process and services is here: https://www.smfcapital.co.uk/smf-recruitment-london/ Thank you for listening to SMF Unlocked. If this episode was useful, share it with a colleague who is hiring or considering an SMF role. Detailed written guides to every Senior Manager Function and the wider SMCR framework are available at smfcapital.co.uk. Until next time.

  4. Oct 10

    Introducing SMF Capital: Specialist Recruitment for FCA-Regulated Firms

    Welcome to SMF Unlocked, the podcast exploring senior management, regulatory accountability and recruitment across UK financial services. In this episode, we’re focusing on SMF Capital: who we are, what we do, and how we help FCA and PRA-regulated firms recruit the senior people they need. That is where specialist recruitment can make a difference. SMF Capital was established to focus on Senior Manager Function appointments, bringing together recruitment expertise and an understanding of the regulatory considerations that influence these hires. What Is SMF Capital? SMF Capital is a specialist recruitment practice working with regulated financial services businesses that need experienced senior managers, executives and board-level professionals. We support firms recruiting across a range of Senior Management Functions, from chief executives and senior finance leaders to compliance officers, money laundering reporting officers, risk professionals and non-executive chairs. Our work spans different types of regulated business, including wealth management, investment management, consumer credit, insurance, banking, payments and fintech. You can find out more about our approach on the SMF Capital website. Why SMF Recruitment Requires a Specialist Approach The Senior Managers and Certification Regime places particular emphasis on individual accountability. For relevant Senior Management Functions, regulatory approval is required before an individual can begin performing the function. The firm must identify the responsibilities attached to the role and provide the regulator with the information needed to assess the appointment. This creates several challenges for employers. First, the job specification must accurately reflect the function and the responsibilities involved. A generic search for a senior executive with financial services experience may not identify candidates with the right regulatory background. Second, the candidate’s experience needs to be examined in context. Having worked at a regulated firm does not automatically mean someone is ready to take on a particular SMF designation at another business. Third, recruitment planning needs to account for the approval process, references and supporting documentation, as well as the normal stages of search, interviews, offer and notice periods. At SMF Capital, we believe these considerations should shape the recruitment process from the beginning rather than being left until a preferred candidate has already been selected. The Senior Management Functions We Recruit SMF Capital works across a broad range of executive and non-executive appointments. Executive and operational leadership. The specific designation depends on the firm and the responsibilities assigned to the individual. Compliance and financial crime Compliance oversight and money laundering reporting are particularly important areas for regulated firms. A strong candidate needs to understand the applicable regulatory framework, but also how to apply it in practice. That may involve building compliance arrangements, managing regulatory relationships, overseeing financial crime controls or supporting a firm through a period of growth and change. Risk, audit and governance Some businesses require specialist risk leadership, internal audit expertise or experienced board committee chairs. These appointments demand candidates who can provide effective challenge, understand the firm’s risk profile and contribute to sound governance. Interim and fractional appointments Not every firm needs a full-time senior manager for every function. Smaller regulated businesses may need experienced interim or fractional support, whether they are filling a vacancy, strengthening governance or managing a period of transition. The suitability of any arrangement depends on the firm's requirements, the relevant regulatory rules and whether the individual has sufficient capacity and authority to perform the function properly. Who Do We Work With? SMF Capital works with firms at different stages of development. A new entrant preparing for FCA authorisation may need to assemble an appropriate senior management team before submitting its application. An established firm may need to replace a departing compliance officer, appoint a new chief executive or strengthen its risk oversight. A growing business may need to review its governance arrangements as its operations become more complex. An overseas firm establishing a UK presence may need senior managers with relevant experience of the UK regulatory framework. Each situation presents different challenges. Our aim is to understand the firm's requirements, identify the relevant responsibilities and find candidates whose experience matches the actual role. Meet the Founder SMF Capital was founded by Adrian Lawrence FCA, a Chartered Accountant and Fellow of the ICAEW, and a former listed-company Finance Director. His background combines senior financial leadership with specialist recruitment. This provides a practical perspective on the challenges boards face when appointing executives and assessing whether a candidate is suitable for a position carrying regulatory accountability. Every SMF search is led personally by Adrian. The intention is to maintain a consistent understanding of the brief, the regulatory context and the candidates being considered throughout the process. That founder-led approach is particularly relevant when a firm needs a candidate with a specific combination of technical experience, leadership ability and regulatory readiness. How SMF Capital Approaches a Search A successful SMF appointment begins with a clear definition of the requirement. We start by understanding the firm, the relevant designation, the responsibilities attached to the position and the experience needed to perform it effectively. We then identify suitable candidates and assess their background against the requirements of the role. Interviews should explore not only professional achievements, but also the individual's judgement, understanding of accountability and readiness for the responsibilities involved. Where appropriate, the process also considers regulatory references and the information needed to support an application. Finally, recruitment planning must account for the regulatory approval timetable. Firms should not assume that making an offer means the individual can immediately start performing an SMF. The objective is to help clients make informed appointments and reduce avoidable surprises later in the process. Part of a Wider Specialist Recruitment Network SMF Capital sits alongside a wider network of specialist recruitment practices. FD Capital focuses on Finance Directors, CFOs and senior finance appointments. Exec Capital covers C-suite and board-level executive search. NED Capital specialises in non-executive directors and governance appointments, while Accountancy Capital recruits qualified finance professionals below director level. This network provides access to complementary expertise across senior leadership and finance recruitment. Where a requirement does not involve a Senior Management Function, the appropriate specialist practice may be better placed to help. The important thing is to match the search to the actual appointment rather than treating every senior role as identical. Why Choose Specialist SMF Recruitment? For a regulated firm, the consequences of a senior appointment extend beyond the usual questions of salary, experience and cultural fit. The individual may need regulatory approval, will have defined responsibilities and must be capable of meeting the expectations associated with the function. A specialist recruiter can help the firm focus its search, understand the candidate market and address regulatory considerations earlier in the process. That does not remove the firm's own responsibilities. The firm remains accountable for its regulatory decisions and must make its own assessment of the candidate's suitability. However, a recruitment process designed around the realities of SMF appointments can help boards and hiring managers make better-informed decisions. Find Out More About SMF Capital If your firm is recruiting a senior manager, planning a new authorisation, reviewing its governance structure or looking for interim or fractional SMF support, we invite you to learn more about our work. Visit SMF Capital on FreeIndex to find our business profile. You can also visit the main SMF Capital website to explore our recruitment services, learn more about the different Senior Management Functions and access our guides to the SM&CR. Whether you are a board member planning a senior appointment, a compliance professional strengthening your team or an experienced executive considering your next SMF role, understanding the requirements is an important first step. Final Thoughts SMF recruitment is a specialist area because these appointments combine leadership, professional experience and regulatory accountability. The right candidate must be able to do the job, understand the responsibilities attached to the role and demonstrate the suitability required for the appointment. SMF Capital exists to help regulated firms navigate that recruitment challenge, with a focus on the specific demands of Senior Management Functions. Thank you for listening to SMF Unlocked. For more information, visit

  5. Oct 10

    Regulatory References: The Six-Year Rule Explained

    Welcome to SMF Unlocked, the podcast from SMF Capital. Today we are looking at an issue that can become particularly important when recruiting senior people into regulated financial services: regulatory references and the FCA's six-year rule. For an individual applying for an SMF, taking on a certification function or moving into another regulated senior position, references are not simply a standard HR formality. The regulatory reference process can provide important information about a person's previous roles, conduct, fitness and propriety. And for employers, understanding the six-year rule is essential. So, what exactly does it mean? What Is the Six-Year Rule? The FCA's regulatory reference requirements are contained in SYSC 22 of the FCA Handbook. The rules apply to SMCR firms and require firms considering appointing someone to certain regulated positions to take reasonable steps to obtain appropriate references from their current employer and previous employers within the preceding six years. That means the reference process can go considerably further back than the candidate's most recent employer. If someone has changed employers several times during the previous six years, the recruiting firm may need to obtain references covering those employers. This is one reason why candidates should keep an accurate record of their employment history. A gap or an overlooked previous employer can potentially complicate the reference process. Why Does the FCA Require Regulatory References? The purpose is fundamentally about fitness and propriety. When a regulated firm appoints someone to an SMF or another relevant position, it needs to have sufficient information to assess whether that person is appropriate for the role. A CV tells you where someone worked and what positions they held. That makes the reference an important part of the wider assessment process. Six Years Does Not Mean Everything Older Is Irrelevant There is an important distinction here. The six-year period is not necessarily a simple rule saying: "Anything more than six years old can never matter." The FCA rules contain an important exception for serious misconduct This is an important point for candidates. A historic issue does not automatically disappear simply because six years have passed. What Does a Regulatory Reference Actually Cover? This is why regulatory references can sometimes feel very different from an ordinary employment reference. A conventional reference might simply confirm: employment dates;job title;salary; andperhaps a brief description of responsibilities.A regulatory reference is concerned with information that may be relevant to the individual's suitability for regulated responsibilities. That is particularly important when the proposed appointment involves significant senior management accountability. What If a Candidate Has a Difficult Reference? Instead, the recruiting firm needs to understand the circumstances and assess the information appropriately. This is where a transparent recruitment process becomes valuable. Trying to hide an issue can potentially create a much bigger problem than the original issue itself. Candidates should be prepared to explain relevant matters accurately and consistently. The recruiting firm should also consider the evidence, context, seriousness, relevance and subsequent history rather than simply reacting to a single sentence in a reference. Regulatory References Must Be Fair and Accurate There is also an important responsibility on the firm providing the reference. The FCA guidance states that references should be true, accurate, fair and based on documented fact. It also recognises that firms may provide frank and honest views, provided reasonable care is taken over factual content and opinions. This matters because regulatory references can have a significant impact on someone's career. A former employer cannot simply use the reference process to make unsupported allegations or provide misleading information. There needs to be a proper basis for what is disclosed. The FCA also notes that firms have duties under general law when preparing references, including a duty to exercise due skill and care. What If the Previous Employer Has No Complete Records? Another practical issue is that employment records may not always go back for the entire period required. A business may have changed systems. Records may have been transferred. A previous employer may have merged with another organisation. Or the candidate may have worked for an overseas business. The FCA rules recognise that firms may not have records covering the maximum periods contemplated by the regulatory reference requirements. Where appropriate, the firm should explain that limitation rather than simply pretending the information does not exist. This is another reason for candidates to provide accurate information about their employment history at the outset. The Rule Also Matters to Employers The six-year rule is not just something candidates need to understand. It matters to recruiting firms too. If a regulated business is considering appointing someone to an FCA controlled function, the reference process needs to be incorporated into the overall appointment timetable. The FCA rules specify when references should be obtained, including in relation to applications for controlled functions. That means recruitment teams should not leave regulatory references until the last minute. An apparently straightforward senior appointment can become delayed if an old employer cannot immediately provide the required information. Planning ahead can make the process considerably smoother. Regulatory References and SMF Recruitment This is one reason why recruiting an SMF is different from ordinary executive recruitment. A successful appointment involves more than identifying someone with the right experience. The firm needs to consider: Does the candidate have the right technical background? Do they have the appropriate seniority? Does their experience match the firm's responsibilities? Can they demonstrate the necessary competence and judgement? What does their regulatory history look like? Are the necessary references available? And ultimately: Is the firm comfortable that the individual is fit and proper for the proposed role? The reference process forms part of that wider assessment. Candidates Should Prepare Early If you are a senior financial services professional considering an SMF appointment, there are several sensible steps you can take. Keep an accurate record of your employment history. Make sure you know which organisations employed you during the previous six years. Understand the regulatory functions you have previously performed. Keep copies of relevant employment and regulatory documentation where appropriate. And if there has been a significant disciplinary, regulatory or conduct issue in your career, make sure you understand exactly what happened and how it was resolved. Being prepared does not mean assuming there will be a problem. It simply means avoiding unnecessary surprises later in the process. SMF Capital's Candidate Perspective At SMF Capital, the recruitment process is focused on senior appointments within regulated businesses. That means understanding the candidate's career history is an important part of identifying an appropriate match. If you are a senior financial services professional considering your next move, the SMF Capital Candidates service provides a route to engage with specialist recruitment focused on Senior Management Functions and regulated leadership positions. The objective is not simply to match a CV with a job description. It is about understanding the candidate's experience, regulatory background, leadership responsibilities and the type of regulated environment in which they are likely to be most effective. You can find out more through the SMF Capital Candidates page. Final Thoughts The FCA's six-year regulatory reference rule is easy to misunderstand. It does not simply mean that every detail of someone's career is examined indefinitely. Nor does it mean that everything disappears after six years. Instead, the framework provides a structured period for obtaining relevant employment and regulatory information, while recognising that serious misconduct may require consideration beyond that period. For employers, the lesson is to build regulatory references into the recruitment and approval timetable. For candidates, the lesson is preparation and transparency. And for both sides, the ultimate objective is the same: making sure the person appointed to a regulated position is genuinely suitable for the responsibilities they are being asked to undertake. If you are a senior professional considering your next regulated appointment, or a firm looking to recruit an SMF, listen to more episodes of SMF Unlocked and explore the specialist services available from SMF Capital. You can also visit the SMF Capital Candidates page to find out more about opportunities and specialist support for senior professionals in regulated financial services. Thank you for listening to SMF Unlock

  6. Oct 10

    SMF Unlocked: The Podcast for FCA Senior Management Functions

    Welcome to SMF Unlocked, the podcast from SMF Capital for anyone involved in FCA Senior Management Functions. If you are a board member, senior executive, compliance professional, HR or governance specialist, investor, or someone considering taking on an SMF appointment, this podcast is designed to make the Senior Managers and Certification Regime easier to understand in practical terms. The aim is straightforward. Rather than simply repeating regulatory terminology, each episode looks at a specific Senior Management Function, a particular regulatory issue or a practical problem that can arise when recruiting and appointing senior people into regulated businesses. You can listen to the full series on the SMF Capital Audioboom channel, where the podcast brings together episodes covering individual SMF designations, FCA authorisation, fit and proper assessments, governance, temporary SMF cover, fractional senior managers and the challenges faced by international firms operating in the UK. Listen to SMF Unlocked on Audioboom Why SMF Appointments Deserve More Attention For many businesses, appointing a senior executive can appear relatively straightforward. You identify the role, find candidates with the right experience, conduct interviews, make an offer and complete the appointment. That means the recruitment process and the regulatory process are closely connected. A candidate can have an impressive career history and still not necessarily be the right person for a particular SMF. The important questions include: Does their experience match the responsibilities of the role? Do they understand the regulatory environment? Can they demonstrate the necessary judgement and competence? Will they have sufficient authority and resources? Are their responsibilities clearly defined? And perhaps most importantly: Does the candidate actually fit the firm's governance structure? These are the kinds of questions that SMF Unlocked explores. There is also an episode on SMF2, examining why a regulated CFO needs more than a traditional finance background. For risk professionals and boards, the podcast explores SMF4, the Chief Risk function, including the importance of having a risk leader capable of providing effective challenge. For board members, SMF9 looks at the Chair function and what changes when the role sits within an SMCR environment. The series also examines SMF16 and SMF17, covering Compliance Oversight and the Money Laundering Reporting Officer function. And for firms operating through UK branches, there is an episode dedicated to SMF19, the Head of Third Country Branch function. This makes the podcast useful not only as a general introduction to SMCR, but also as a reference library for particular appointments. Beyond Individual SMF Designations SMF Unlocked is not only about individual job titles. Some of the most important questions arise from the way the functions fit together. For example, what happens when a business is moving from a Core to an Enhanced SMCR structure? How should a firm think about building a multi-SMF team? Is the firm's Responsibilities Map actually fit for purpose? What happens when an SMF holder unexpectedly leaves? When might temporary or fractional senior management support be appropriate? And how should an overseas firm structure its UK branch and senior management responsibilities? These are practical questions that can become very important when a regulated business is growing, restructuring or preparing for FCA authorisation. The Recruitment Perspective There is another reason for creating the podcast. SMF appointments are ultimately about people. Equally, a candidate from a smaller firm may have precisely the hands-on experience required by another business. The right assessment therefore needs to look beyond job titles. It should consider the candidate's actual responsibilities, regulatory exposure, leadership experience, technical knowledge, decision-making authority and ability to operate within the firm's governance structure. That is particularly important for smaller firms, where one senior individual can sometimes have a very significant influence on the overall regulatory framework. Who Is SMF Unlocked For? The podcast is intended for a broad professional audience. Boards and Non-Executive Directors If you sit on the board of a regulated business, understanding the responsibilities attached to senior management functions can help you ask better questions about governance and appointments. CEOs and Senior Executives If you are considering an SMF appointment, the podcast provides a practical introduction to the responsibilities and considerations surrounding different functions. Compliance and Risk Professionals For people progressing towards senior regulatory positions, the individual SMF episodes provide useful context around the expectations associated with particular functions. HR and Recruitment Teams SMF recruitment involves considerations that go beyond an ordinary executive search. Understanding the regulatory designation and the responsibilities attached to it can make the recruitment process considerably more effective. Firms Preparing for FCA Authorisation For a new regulated business, the senior management structure should not be an afterthought. The right people, responsibilities and governance arrangements need to be considered as part of the wider authorisation process. What Makes the Podcast Different? There are plenty of sources of regulatory information. The purpose of SMF Unlocked is not to compete with the FCA Handbook or formal regulatory guidance. Instead, the podcast takes those requirements and asks: What does this mean when you actually have to appoint someone? What should a board look for? What experience matters? Where can responsibilities become blurred? What can go wrong? And how can a firm build a senior management structure that works in practice rather than simply looking correct on paper? That practical perspective is particularly relevant because SMF Capital specialises in senior-level recruitment for regulated businesses. The podcast is therefore closely connected to the real-world challenges encountered during senior management searches. Building a Library of SMF Knowledge The series is also designed to become a continuing reference library. As the regulatory environment develops, new episodes can examine changes affecting senior management functions, governance, authorisation and recruitment. For someone researching an SMF appointment today, that means the podcast can provide a starting point. You might begin with the general introduction to SMF authorisation, then listen to the episode covering the particular function you are interested in. From there, you can explore related subjects such as the fit and proper test, responsibilities, governance structures, temporary cover or recruitment. The result is a growing collection of short, focused discussions rather than one long programme trying to explain everything about SMCR in a single episode. SMF Capital SMF Unlocked is produced by SMF Capital, a specialist UK recruitment practice focused on FCA Senior Management Function appointments. The wider SMF Capital service covers areas including SMF recruitment, FCA authorisation support, governance and senior management structures, and fractional or interim SMF cover. That creates a natural connection between the podcast and the practical services required by regulated firms. If you are listening because your business is preparing for an appointment, restructuring its senior management team or looking for a particular SMF candidate, the podcast can help you understand the issues you should be considering before beginning the search. Final Thoughts Senior Management Functions are ultimately about accountability. The FCA framework may define the functions, but the effectiveness of that framework depends heavily on the people occupying those positions and the governance structure around them. That is why understanding an SMF appointment is important for more than just the individual candidate. It matters to the board. It matters to shareholders and investors. It matters to compliance and risk teams. And it matters to the firm as a whole. SMF Unlocked is designed to make those issues easier to understand, one function and one practical question at a time. If you are involved in FCA-regulated financial services, recruiting senior leaders, considering an SMF appointment or preparing a business for authorisation, listen and subscribe to the SMF Capital podcast on Audioboom. Listen to SMF Unlocked on Audioboom And for further information on Senior Management Functions and specialist recruitment support, visit SMF Capital. Visit SMF Capital Thank you for listening to SMF Unlocked.

  7. Oct 10

    The Conduct Rules Every Senior Manager Must Know

    Welcome to SMF Unlocked, the podcast from SMF Capital. Today we are looking at one of the most important aspects of being an FCA Senior Management Function holder: the Conduct Rules. For an SMF, regulatory responsibility is not simply about having a particular job title or being approved by the FCA. Senior managers are subject to specific standards of behaviour and have personal accountability for the areas of the business for which they are responsible. The FCA's Conduct Rules set minimum standards of individual behaviour, while SMF holders are also subject to four additional Senior Manager Conduct Rules. So what do those rules actually mean in practice? The Six Individual Conduct Rules The FCA's individual Conduct Rules apply broadly across relevant staff within SMCR firms. They require individuals to: Act with integrity.Act with due skill, care and diligence.Be open and cooperative with the FCA, the PRA and other regulators.Pay due regard to the interests of customers and treat them fairly.Observe proper standards of market conduct.Act to deliver good outcomes for retail customers, where the relevant Consumer Duty requirements apply.For an SMF holder, these principles form the foundation. But there is another layer. Senior managers have four additional rules specifically concerned with the responsibilities they carry. Senior Manager Conduct Rule One: Effective Control The first Senior Manager Conduct Rule is: You must take reasonable steps to ensure that the business of the firm for which you are responsible is controlled effectively. This is a fundamental principle of senior management accountability. The FCA does not expect an SMF holder to personally perform every task within their area. A CEO cannot personally monitor every transaction. A CFO cannot personally check every financial entry. A Chief Risk Officer cannot personally assess every risk. Instead, the requirement is to take reasonable steps to ensure that the business is properly controlled. Senior Manager Conduct Rule Two: Regulatory Compliance The second rule requires an SMF to: Take reasonable steps to ensure that the business for which they are responsible complies with the relevant requirements and standards of the regulatory system. This does not mean that every senior manager needs to be a regulatory lawyer. Senior Manager Conduct Rule Three: Delegation The third rule is particularly important for senior executives: You must take reasonable steps to ensure that any delegation of your responsibilities is to an appropriate person and that you oversee the discharge of the delegated responsibility effectively. Delegation is unavoidable in most substantial financial services businesses. A senior manager simply cannot do everything personally. But delegation does not mean abandoning responsibility. The person receiving the delegated responsibility needs to be appropriate for the task, and the senior manager needs to retain sufficient oversight. That creates an important distinction between delegating a task and transferring accountability. An SMF might delegate operational activity to a senior member of their team, but they still need to understand what is happening within the area for which they remain accountable. The FCA specifically warns that delegation does not remove an SMF holder's accountability. Senior Manager Conduct Rule Four: Disclosure The fourth rule requires an SMF to: Disclose appropriately any information of which the FCA or PRA would reasonably expect notice. This is about ensuring that important information reaches the regulator when appropriate. That reinforces a wider principle running through the SMCR: Senior managers need to be informed about the businesses they are responsible for. The Importance of "Reasonable Steps" One phrase appears repeatedly in the Senior Manager Conduct Rules: reasonable steps. This is important because the FCA is not saying that a senior manager must guarantee that nothing ever goes wrong. Financial services businesses are complex. Mistakes happen. Systems fail. Employees make errors. Customers complain. Regulatory breaches can occur. The question is whether the senior manager took appropriate and proportionate steps given the circumstances and the responsibilities allocated to them. That makes the quality of management particularly important. An SMF should have appropriate information, monitoring, escalation and challenge mechanisms. If something significant happens, they need to respond appropriately. Your Statement of Responsibilities Matters The Conduct Rules cannot be considered separately from an SMF holder's Statement of Responsibilities. The FCA requires every SMF to have a Statement of Responsibilities setting out what they are responsible and accountable for. This provides an important link between the firm's governance structure and the individual's personal responsibilities. Conduct Is More Than Financial Misconduct Another important development is the FCA's approach to non-financial misconduct. New rules and guidance concerning non-financial misconduct came into effect on 1 September 2026. For non-banking firms within the relevant SMCR framework, the Conduct Rules now cover certain bullying, harassment or violence towards colleagues where there is a sufficient work-related link. This reflects the broader regulatory focus on workplace culture and individual behaviour. For senior managers, conduct therefore extends beyond obvious financial or regulatory breaches. Leadership behaviour, decision-making, treatment of colleagues and the response to inappropriate behaviour can all become relevant depending on the circumstances. What Happens If an SMF Breaches the Rules? A breach of the Conduct Rules can have serious consequences. The FCA states that disciplinary action can include a fine, restrictions, a prohibition on carrying out certain activities or withdrawal of approval. Firms also have obligations concerning disciplinary action arising from Conduct Rule breaches. This reinforces why Conduct Rules should not be treated as a box-ticking exercise. For someone considering an SMF appointment, understanding the rules before accepting the role is important. What Does This Mean for Recruitment? For firms recruiting an SMF, the Conduct Rules provide another reason to look beyond the candidate's CV. A candidate may have impressive technical qualifications and many years of industry experience. But the firm also needs to consider whether the individual has demonstrated the judgement and leadership capability necessary to operate under a regime of personal accountability. Can they challenge difficult decisions? Do they understand risk? Can they delegate effectively? Will they escalate problems? Are they comfortable dealing directly with regulators? And will they take responsibility when something goes wrong? These characteristics can be just as important as technical expertise. Preparing for an SMF Appointment For candidates, understanding the Conduct Rules before entering an SMF role can be extremely valuable. You should understand your Statement of Responsibilities. You should know what areas of the business you are accountable for. You should understand how responsibilities are delegated. You should know how material issues are escalated. And you should be confident that you have sufficient authority, resources and information to discharge the responsibilities attached to your position. If those things are not clear before accepting the role, they are worth discussing. SMF Capital SMF Capital specialises in senior-level recruitment for regulated businesses. That means helping firms identify candidates who have not only the technical experience required for a position, but also the leadership capability and regulatory understanding required to operate effectively within an SMCR environment. For candidates, the same principle applies. An SMF appointment is a significant career step and should be approached with a clear understanding of the responsibilities involved. The Conduct Rules Explained resource provides further information on who the Conduct Rules apply to and what they require. Final Thoughts The Conduct Rules are ultimately about how senior people behave when they have responsibility for a regulated business. For an SMF holder, the four additional Senior Manager Conduct Rules can be reduced to four important questions: Is the business properly controlled? Is it complying with the relevant regulatory requirements? Are responsibilities being delegated appropriately and overseen effectively? And is important information being disclosed to the regulator when it should be? Those questions sit at the heart of individual accountability under the SMCR. That concludes this episode of SMF Unlocked. For more information, visit SMF Capital and explore the specialist resources and recruitment services available for regulated senior management appointments. Thank you for listening.

  8. Oct 3

    From Core to Enhanced — Building a Multi-SMF Team

    Welcome to the SMF Capital podcast. Today we're looking at a transition that can significantly change the senior management structure of a regulated business: moving from Core to Enhanced SM&CR status. For a growing financial services firm, reaching the point where enhanced requirements apply is an important stage of development. It can mean additional Senior Management Functions, more formal allocation of responsibilities and a greater need for a coordinated board and executive structure. The FCA currently categorises solo-regulated firms as Enhanced, Core or Limited Scope, with Enhanced firms subject to additional requirements reflecting their greater size, complexity or potential impact on consumers or markets. The 2026 SM&CR reforms also raised a number of thresholds for becoming an Enhanced firm, meaning businesses should monitor their position rather than assuming that historic thresholds still apply. Today we'll look at what happens when a firm needs to build several SMF roles rather than recruit one senior manager at a time. Why Core-to-Enhanced Is Different A Core firm may have a relatively compact senior management structure. As the business grows, however, its regulatory obligations and governance requirements can become more extensive. Moving into Enhanced scope can bring additional SMF requirements and responsibilities into the firm's structure. The challenge is that these appointments don't exist independently. The Chief Executive needs to work effectively with the Chief Risk Officer. Risk needs to interact with Compliance. Operations needs to work alongside Risk and Technology. The board needs clear visibility across all of these functions. This means that simply launching several separate recruitment searches may not produce the best overall result. The firm needs to consider the team as a whole. What Does an Enhanced Firm Need to Consider? The exact SMF requirements depend on the firm's regulatory status, activities and circumstances. Enhanced firms can have additional Senior Management Functions and prescribed responsibilities compared with Core firms. The objective is straightforward: There should not be uncertainty about who is responsible for what. That can leave the business operating with an incomplete senior management structure for an extended period. A coordinated multi-SMF programme takes a different approach. The firm identifies the roles it expects to need, maps the responsibilities, establishes the desired board structure and then sequences the recruitment process accordingly. Why Board Dynamics Matter Senior appointments cannot be assessed entirely in isolation. A candidate may have an excellent individual CV but still be unsuitable for the particular team. The question is not only: "Can this person perform the SMF?" It is also: "How will this person work with the other SMF holders?" A Chief Executive and Chief Risk Officer, for example, need to be able to challenge one another constructively. A Compliance Oversight function needs sufficient independence while still working effectively with executive management. The board needs a mixture of expertise, challenge and collaboration. That is why a multi-SMF recruitment project should consider the resulting team rather than simply the individual vacancies. Consistency in Fit and Proper Assessment Another advantage of a coordinated search is consistency. The FCA requires SMF candidates to be fit and proper before they are approved, and every SMF holder has a Statement of Responsibilities setting out what they are responsible and accountable for. When several SMFs are recruited independently, there is a risk that different standards or assessment processes are applied to different candidates. A coordinated process allows the firm to establish the requirements for the whole leadership team from the outset. The recruitment assessment can then consider: Technical competenceRegulatory experienceLeadership capabilityRelevant sector knowledgeGovernance experienceIndependence and judgementBoard and executive working relationshipsThis creates a much more coherent appointment process. The Importance of Responsibilities Mapping When several SMFs are being appointed, responsibility mapping becomes particularly important. The FCA's rules require firms to allocate responsibilities systematically and explicitly, with appropriate coverage of the firm's activities and management functions. This means that recruitment and governance should work together. If the firm is recruiting an SMF4 Chief Risk Officer, for example, it should understand how that responsibility interacts with the Chief Executive, Compliance Oversight and other senior managers. The same principle applies to operations, finance, financial crime and other functions. The objective is to create a structure where responsibilities are clear and meaningful. Don't Recruit the Titles — Recruit the Structure One of the biggest mistakes in a multi-SMF recruitment exercise can be starting with job titles. Instead, start with the firm's requirements. What has changed as the business has grown? Which areas now require dedicated senior oversight? Where are the existing responsibilities allocated? Where are the gaps? Which functions need additional independence? Which roles need to interact closely? Once those questions have been answered, the appropriate SMF structure becomes much clearer. The recruitment process can then identify people who fit that structure. Timing Multiple SMF Appointments Timing is another important consideration. Several SMF applications reaching the regulator at approximately the same time need to be properly coordinated. The firm needs to ensure that each application is complete, that responsibilities are clearly documented and that the candidates are ready for the approval process. A coordinated recruitment programme allows the business to work backwards from its desired governance structure and build a realistic timetable. It can also reduce the risk of one appointment being completed months before another, leaving the firm with a partially refreshed senior team. What About Existing SMF Holders? A Core-to-Enhanced transition does not necessarily mean replacing the existing leadership team. Existing SMF holders may remain entirely appropriate. The question is whether their responsibilities, experience and authority continue to fit the firm's new structure. Some responsibilities may need to be redistributed. Additional SMFs may need to be appointed. The firm's Statements of Responsibilities and, where applicable, its Responsibilities Map may also need to be updated. This is therefore both a recruitment exercise and a governance exercise. Multi-SMF Recruitment With SMF Capital SMF Capital supports firms that need to build several senior management positions as part of a wider governance change. Our Multi-SMF Board & Executive Team Build service is designed for situations such as Core-to-Enhanced transitions and coordinated board refreshes. Rather than treating each vacancy as a completely separate project, the process considers the overall senior management structure, sequencing the searches and assessing how the resulting team will work together. You can explore the service here: https://www.smfcapital.co.uk/multi-smf-board-executive-team-build/ Permanent SMF Recruitment For firms that have individual SMF vacancies, SMF Capital also provides specialist SMF Recruitment Services. The service covers senior management recruitment across a range of regulated functions, with fit-and-proper considerations built into the recruitment process from the outset. You can find out more here: https://www.smfcapital.co.uk/smf-recruitment-services/ Final Thoughts Moving from Core to Enhanced is more than a regulatory classification change. For a growing firm, it can be an opportunity to review whether the senior management structure still reflects the scale and complexity of the organisation. Additional SMFs may need to be appointed. Existing responsibilities may need to be reconsidered. And the board and executive team need to work effectively as a whole. The FCA's current framework continues to emphasise individual accountability, clear allocation of responsibilities and appropriate senior management oversight, while the 2026 reforms have changed aspects of how Enhanced firms are defined and how the regime operates. For firms approaching an Enhanced threshold, planning early can make the transition considerably more structured. Rather than recruiting one SMF at a time, a coordinated approach can look at the whole senior management team, the responsibilities it needs to carry and how those individuals will operate together. If your firm is approaching a Core-to-Enhanced transition or planning a wider board and executive refresh, visit SMF Capital's Multi-SMF Board & Executive Team Build service. For individual appointments, explore SMF Recruitment Services. SMF Capital — specialist recruitment for Senior Management Functions and regulated leadership teams.

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.