SMCR Accountabilities

SM&CR Responsibilities & Regulatory Accountabilities (SMF16 & SMF17)

As the FCA-approved Senior Manager performing the SMF16 (Compliance Oversight) and SMF17 (Money Laundering Reporting Officer) functions, the post holder will be responsible for maintaining an effective compliance and financial crime framework, ensuring the firm meets its regulatory obligations and delivers good customer outcomes.

The role includes responsibility for:

• Providing independent oversight of the firm's compliance with FCA rules, legislation and regulatory requirements.
• Establishing and maintaining effective compliance systems, controls and a risk-based Compliance Monitoring Programme.
• Providing independent regulatory advice and challenge to senior management and the Board.
• Overseeing the firm's Consumer Duty framework and monitoring customer outcomes.
• Ensuring effective oversight of the firm's Appointed Representative and outsourced regulated activities.
• Acting as the firm's Money Laundering Reporting Officer (MLRO), overseeing the AML, CTF, sanctions and financial crime framework, including customer due diligence, suspicious activity reporting and regulatory compliance.
• Monitoring regulatory developments and ensuring appropriate implementation of legislative and regulatory changes.
• Reporting material compliance and financial crime risks to the Board and, where required, the FCA and other relevant authorities.
• Promoting a strong culture of compliance, integrity and ethical conduct throughout the organisation.

Required Experience and Qualifications

Experience & Qualifications

Essential

• Significant experience within an FCA-regulated financial services environment, preferably consumer credit, debt collection, debt administration or a related sector.
• Strong working knowledge of the FCA Handbook, including CONC, SYSC, DISP, Consumer Duty and SM&CR.
• Experience of developing, implementing or monitoring compliance frameworks, policies and controls.
• Experience of undertaking compliance monitoring, regulatory advice and risk assessments.
• Good understanding of Anti-Money Laundering (AML), sanctions, customer due diligence and financial crime requirements.
• Experience of preparing management information and presenting compliance matters to senior management.
• Excellent communication, analytical and stakeholder management skills.

Desirable

• Previous experience operating within a Principal/Appointed Representative model.
• Experience of working with outsourced or offshore operational teams.
• Experience of FCA authorisations, supervisory engagement or regulatory change programmes.
• Experience acting as an MLRO, Deputy MLRO or Compliance Manager.
• Knowledge of debt collection or debt administration activities.

Qualifications

• Degree or equivalent professional experience.
• Professional compliance qualification or working towards one.
• AML or Financial Crime qualification desirable.
• Eligibility to obtain FCA approval as an SMF16 and SMF17.

Key Competencies

Key Competencies

• Commercial Awareness – Able to provide pragmatic, risk-based regulatory advice that supports business growth while ensuring compliance with FCA requirements.
• Regulatory Expertise – Strong understanding of the FCA regulatory framework, Consumer Duty, SM&CR, AML and financial crime requirements, with the ability to interpret and apply regulatory change effectively.
• Risk-Based Decision Making – Able to assess regulatory and financial crime risks, balancing customer outcomes, regulatory obligations and commercial objectives.
• Independent Judgement & Integrity – Confident in providing objective advice and constructive challenge to senior management and the Board while maintaining professional independence.
• Leadership & Influencing Skills – Able to build credibility, influence stakeholders at all levels and foster a positive culture of compliance and ethical behaviour.
• Analytical Thinking – Strong ability to interpret data, identify trends, investigate issues and recommend practical, proportionate solutions.
• Communication Skills – Excellent written and verbal communication skills with the ability to explain complex regulatory matters clearly to both technical and non-technical audiences.
• Governance & Organisational Skills – Strong planning and organisational capability with the ability to manage multiple priorities, meet deadlines and maintain high standards of governance.
• Relationship Management – Builds effective working relationships across the business, supporting collaboration while maintaining appropriate independence.
• Continuous Improvement – Proactively identifies opportunities to strengthen governance, improve processes and enhance customer outcomes.

Contractual and Approval Requirements

The appointment to this role is conditional upon:

• FCA approval of the candidate to perform the SMF 16/17 obtained by the firm via the submission of Form A prior to the commencement of the role;
• Submission to the FCA of an accurate and complete Statement of Responsibilities covering the SMF 16/17 function;
• Satisfactory completion of criminal record checks via the Disclosure and Barring Service (and any overseas equivalent as appropriate);
• Satisfactory regulatory reference checks going back six years, obtained in accordance with SYSC 22; and
• The firm's own fitness and propriety assessment confirming the candidate's suitability.