Financial Services Executive Search

Financial Services Executive Search

Financial services executive search is not a variant of general executive search with a sector overlay. The regulatory framework — the Senior Managers and Certification Regime (SMCR), the FCA’s accountability expectations, the ICAAP and ILAAP requirements at banks and the ICARA process at MIFIDPRU investment firms, and the conduct and culture obligations — shapes what executives in the sector must be capable of in ways that candidates from outside financial services cannot replicate quickly. The CRO who has never presented to the regulator, the CFO who does not understand MIFIDPRU capital reporting, the CEO who has never been through a skilled person review — these gaps become visible and consequential faster in financial services than in almost any other sector. Finding executives who are genuinely calibrated to the specific regulatory environment of the appointing firm requires a search firm with direct experience of that environment. To discuss your requirement, call 0203 834 9616.

Exec Capital recruits C-suite and senior executives for FCA-regulated firms, PRA-regulated banks and insurers, wealth managers and family offices, fintech and payment businesses, and financial services technology companies across the UK. We recruit across CEO, CFO, COO, CRO, Head of Compliance, MLRO, and specialist functional appointments, on permanent, interim and fractional terms. Every search is run by our specialist team, with Adrian Lawrence FCA overseeing each mandate.

Fractional and interim SMF16 and SMF17: the most common starting point

The appointment we are asked about most often across the group is not a CEO or a CFO. It is a compliance oversight (SMF16) holder and a Money Laundering Reporting Officer (SMF17) for a smaller authorised firm — frequently combined in one person, and frequently on a part-time basis. Small investment firms, IFAs and wealth planners, insurance and credit brokers, consumer credit firms and early-stage regulated businesses need both functions approved and properly discharged, but rarely have a full-time workload for either. A fractional compliance officer working a set number of days a month gives the firm an experienced, approved individual without a full-time salary.

Whether one person can hold both functions depends on the size and complexity of the firm and on the time the individual can genuinely commit. Our guide to SMF16 vs SMF17 and when to combine them sets out how firms and the FCA tend to look at it. The routes we run most often are:

• Fractional SMF16 / Head of Compliance — a senior compliance professional on a regular days-per-month basis who holds the compliance oversight function, runs the monitoring plan and reports to the board. See fractional CCO.
• Fractional MLRO (SMF17) — an approved MLRO who owns the firm-wide AML risk assessment, suspicious activity reporting and the annual MLRO report. See fractional MLRO and part-time MLRO.
• Combined fractional SMF16/17 — one individual approved for both functions at a firm where the combined workload fits a part-time commitment.
• Interim cover — a full-time or near-full-time compliance leader brought in when the incumbent leaves unexpectedly, during a remediation or ahead of a regulatory visit. See interim CCO and our guide to interim SMF16/SMF17 cover.

Under the FCA’s current proposals for the next phase of SMCR reform (CP26/37, published October 2026), some board-level functions at larger firms would move from pre-approval to notification, but the compliance oversight function (SMF16) and the MLRO function (SMF17) remain functions that require FCA approval before the individual starts. That keeps the quality of the candidate — and their approval history — central to any compliance appointment.

Why financial services executive search requires a specialist

Three features of the financial services executive environment make specialist search a material advantage over generalist search for this sector.

Regulatory personal accountability — the Senior Managers and Certification Regime attaches personal regulatory accountability to senior executives in FCA and PRA-regulated firms in a way that has no equivalent in other sectors. An SMF holder who does not understand the personal accountability dimension of their role will make governance errors that are visible to the FCA and consequential to the firm. Assessing candidates for this understanding — and finding those who have operated under SMCR rather than those who have read about it — requires a search firm whose own practice is embedded in the regulatory environment.

Candidate pool specificity — the executives who are qualified for senior roles at regulated firms are a substantially smaller pool than the broader senior executive market because the regulatory qualification criterion (direct FCA or PRA-regulated experience) removes the majority of the corporate executive market from consideration. Accessing this pool — particularly the most senior and most qualified candidates who are not actively visible in the market — requires direct network relationships that a generalist search firm operating across all sectors cannot maintain at the depth the financial services market requires.

FCA approval timeline integration — many senior financial services executive appointments require regulatory approval, through a Form A application, before the individual can take up the role. A search that does not build the approval timeline into the process from the brief stage will consistently underestimate the appointment timeline and create governance gaps while the approval process runs. Exec Capital builds the FCA approval process into every regulated firm mandate from day one. Our guide to how long FCA SMF approval takes explains the timings in more detail.

There is a fourth, practical reason. Regulated firms are judged on the quality of their senior people by a supervisor who reads the CV, the regulatory references and the Statement of Responsibilities. A weak appointment does not simply underperform; it can draw supervisory attention, delay a variation of permission or an authorisation application, and in the worst case lead to a withdrawn application that the individual and the firm both have to explain later. A search firm that understands fitness and propriety, and knows which questions a supervisor will ask at interview, reduces that risk before the application is ever submitted.

How a financial services search works

Every mandate follows the same broad sequence. What changes from firm to firm is the regulatory overlay — whether the role is a Senior Management Function, who the regulator is, and whether temporary cover is needed while approval runs. We agree the timetable with you at briefing and keep the approval steps in view throughout.

Financial services sub-sectors we recruit across

Asset management and wealth management — including institutional asset managers, wealth managers, discretionary investment managers, and multi-family offices. The executive leadership requirements in this sub-sector combine investment knowledge, regulatory awareness, and the client relationship management capability that UHNW and institutional clients demand. See our FCA Regulated Firm Recruitment hub and our Family Office Executive Search hub, along with our dedicated asset management recruitment and wealth management recruitment pages.

Fintech and payment institutions — including e-money institutions, payment service providers, and financial technology businesses that hold FCA authorisation or registration under the Payment Services Regulations or Electronic Money Regulations. The executive leadership requirements in this sub-sector combine technology leadership, commercial growth orientation, and the regulatory awareness required to manage the FCA relationship in an environment where regulatory expectations are evolving rapidly. Payment and e-money institutions sit outside SMCR: they appoint an MLRO under the Money Laundering Regulations, and the FCA assesses the people responsible for managing the business as part of authorisation, but not as Senior Management Functions. Fintechs that also hold FSMA permissions (for example for lending or investments) are within SMCR for that entity. See fintech recruitment and our guide to senior hiring at payment institutions.

Consumer credit and lending — including consumer credit lenders, mortgage brokers, and specialist finance businesses authorised by the FCA and subject to the Consumer Credit Act. The executive leadership requirements in this sub-sector are shaped by Consumer Duty implementation, CONC obligations, and the FCA’s increasing focus on consumer outcomes in the lending market.

Insurance intermediaries and brokers — including general insurance brokers, Lloyd’s market participants, and specialist insurance intermediaries. The executive leadership requirements combine underwriting knowledge, FCA regulatory awareness, and the client relationship management skills that the broker market demands. Insurers and managing agents add PRA-specific functions such as the Chief Actuary and Chief Underwriting Officer. See insurance recruitment.

Banking and prudentially regulated institutions — including UK-regulated banks, building societies, and credit unions. The executive leadership requirements combine PRA regulatory knowledge, prudential risk management capability, and the governance standards that PRA supervision requires of senior management. See commercial banking recruitment.

Digital assets — cryptoasset firms are being brought into the FCA’s authorisation regime and, under the FCA’s proposals, into SMCR. Boards building a senior team for authorisation need people who can stand up to a first-time approval process. See digital assets executive recruitment.

Financial services executive appointments we run

CEO of FCA-Regulated Firm — SMF1, the most senior regulated firm appointment. See our CEO of FCA-Regulated Firm Recruitment page.

Chair of a regulated firm (SMF9) — the chair of the governing body, a pre-approved function at firms within SMCR. See chair of regulated firm recruitment and our SMF9 chair hiring guide.

Executive Director (SMF3) — executive board directors who do not hold another designated SMF; at Core firms this is often how a board-level CFO is approved. See executive director recruitment for FCA firms and the SMF3 hiring guide.

Chief Risk Officer (SMF4) — second-line risk leadership and Risk Committee governance. SMF4 is a designated function at banks, insurers and Enhanced firms; at Core firms the risk lead is usually not a separate SMF, although the role is just as important. See our CRO Recruitment page, our interim CRO page and the SMF4 CRO hiring guide.

Head of Compliance (SMF16) — compliance function leadership and FCA regulatory relationship management. See our Head of Compliance (SMF16) Recruitment page, and the compliance and risk recruitment hub.

MLRO (SMF17) — Money Laundering Reporting Officer and AML framework leadership. See our MLRO Recruitment (SMF17) page.

Chair of the Remuneration Committee (SMF12) — an independent non-executive function at Enhanced and dual-regulated firms. See SMF12 remuneration committee chair.

Head of Third Country Branch (SMF19) — the senior individual responsible for the UK branch of an overseas bank or insurer. See SMF19 recruitment.

Chief Actuary (SMF20) and Chief Underwriting Officer (SMF23) — PRA-designated insurance functions. See SMF20 Chief Actuary recruitment and SMF23 Chief Underwriting Officer recruitment.

COO of FCA-Regulated Firm — operational leadership at regulated firms. The Chief Operations function (SMF24) applies at dual-regulated and Enhanced firms; at Core firms a COO who sits on the board is typically approved as SMF3. See our COO of FCA-Regulated Firm Recruitment page.

Financial Services NED — independent non-executive governance for regulated firm boards. See our Financial Services NED Recruitment page.

CISO — information security governance under the FCA and PRA operational resilience rules (FCA PS21/3), and under DORA and NIS2 where the group has EU-regulated entities. See our CISO Recruitment page.

SMF roles at a glance: which functions apply to which firms

One of the commonest errors in a regulated-firm brief is assuming that every firm has every function. It does not. Which SMFs apply depends on whether the firm is dual-regulated (banks, building societies, insurers and PRA-designated investment firms) or solo-regulated by the FCA, and, if solo-regulated, whether it is a Limited Scope, Core or Enhanced firm. The table below summarises the functions we recruit for most often. Our SMF roles guide covers the full list.

Payment institutions and e-money institutions are not on this table because they are outside SMCR altogether. The consultation also proposes raising the thresholds for Enhanced status, which would move some firms to Core and change which functions they need, so a brief written today should be checked again when the final rules are published, expected in the first half of 2027. The PRA’s parallel paper, CP14/26, covers dual-regulated firms.

The SMCR dimension of financial services executive search

The FCA’s Senior Managers and Certification Regime is the defining regulatory framework for executive appointments in UK-regulated financial services. SMCR applies to firms authorised under the Financial Services and Markets Act, across Limited Scope, Core and Enhanced classifications for solo-regulated firms and a separate regime for dual-regulated banks and insurers. It attaches personal regulatory accountability to designated Senior Management Functions and requires regulatory approval for SMF holders before they perform the designated function. Payment and e-money institutions authorised only under the payment services and e-money regimes are outside it.

Every financial services executive search we run at a regulated firm is conducted with full awareness of the SMCR implications: the candidate’s approval status, the Form A submission requirements, the Statement of Responsibilities drafting, the regulatory references process, and the regulator’s assessment timeline. We do not treat these as administrative matters to be addressed at the end of the search — we build them into the process from the initial brief and manage the regulatory pathway alongside the search itself.

What has changed in the regime

SMCR is in the middle of its most significant reform since it was introduced. The first phase, set out in the FCA’s policy statement PS26/6, took effect on 24 April 2026. For hiring, the most important change concerns temporary cover: under SUP 10C.3A.6R a firm that loses an SMF holder unexpectedly can have someone cover the role while it prepares an application, and now has 12 weeks to submit that application, with the cover continuing until the regulator decides it. The second phase consultation, CP26/37, proposes extending that window to 18 weeks and removing the requirement that the absence be unforeseen. It closes on 22 January 2027.

The legal timetable for a decision is set by section 61 of FSMA: the regulator must determine a complete application within three months, with the clock stopping while it waits for information it has asked for. In practice decisions are usually faster. The FCA’s published operating service metrics for 2025/26 show a median of about 25 days for senior manager approvals across the year, with quarterly medians of 38, 28, 16 and 19 days. Incomplete applications, unclear Statements of Responsibilities and late regulatory references are the usual reasons an individual case takes longer, which is why we prepare for them during the search.

Permanent, interim, fractional or part-time: choosing the format

A financial services hire does not have to be a full-time permanent appointment. Many firms combine formats — an interim leader to stabilise a function while the permanent search runs, or a fractional compliance officer until the firm grows enough to justify a full-time hire. Approval requirements are the same whichever format you choose: a fractional SMF16 holder needs the same approval as a full-time one, and must be able to show the regulator that the time committed is enough for the role.

Our guide to choosing between a permanent, interim or fractional compliance hire covers the trade-offs in more depth, and the fractional, interim and permanent guide applies the same reasoning to the wider C-suite. Where an SMF holder has left and the firm needs someone in seat quickly, our urgent SMF appointment page explains how temporary cover and a parallel permanent search can run together.

What a new senior hire typically delivers in the first 90 days

The first three months of a regulated-firm appointment look different from a non-regulated one because so much of the early work is about understanding, and taking ownership of, the regulatory position. The detail depends on the role, but a well-chosen hire will usually cover the following.

• Days 1–30: understand the position. Review the firm’s permissions, the last supervisory correspondence, open regulatory actions, the compliance monitoring plan, the AML business-wide risk assessment, the risk register and board and committee papers. Agree the Statement of Responsibilities and confirm the handover from any temporary cover.
• Days 31–60: set priorities. Identify the material gaps — Consumer Duty evidence, financial crime controls, capital and liquidity reporting, operational resilience mapping, outsourcing oversight — and agree a prioritised plan with the CEO and board.
• Days 61–90: deliver and report. Close the quick wins, take the first full report to the board or relevant committee, and set the reporting rhythm the regulator will expect to see. For a compliance or MLRO hire this usually means a refreshed monitoring plan and a clear view of the next annual MLRO report.

For fractional appointments the same ground is covered over more calendar time, which is why the days committed at the outset matter. A fractional SMF16 working two days a month cannot do a 90-day diagnostic in 90 days; the plan is agreed with that in mind. Our executive onboarding guide has more on structuring the first months.

Working with Exec Capital on financial services mandates

Every financial services mandate is run by our specialist team, with Adrian Lawrence FCA overseeing each mandate. The combination of ICAEW fellowship, direct experience in regulated environments, and sustained sector specialism means that Exec Capital brings genuine regulatory understanding to every financial services search — not a financial services overlay applied to a generalist search methodology.

Exec Capital is part of FD Capital Group, a group of specialist firms that also covers finance leadership, non-executive appointments and senior manager function hiring. That gives each financial services search access to a shared network of finance directors, compliance leaders and board members, many of whom also sit as non-executives. We are an executive search firm: we do not provide compliance consultancy, legal advice or regulatory application services, and we work alongside your lawyers and compliance advisers where an application needs them.

Engagement and fees

How we work is agreed at briefing and confirmed in writing before the search starts. The fee structure is agreed with you at that stage, according to the role, the format and the scope of the search.

• Retained search is our usual approach for permanent board and SMF appointments, where the candidate pool is small and most suitable people are not actively looking. It gives the search a defined scope, a dedicated process and regular reporting.
• Contingent support can suit some below-board appointments where the market is more visible. Our retained vs contingent executive search guide explains the differences.
• Interim and fractional appointments are charged on a day-rate basis. The day rate you pay includes our fee, so there is one rate to budget for, and the commitment (days per week or month) is agreed at the outset.
• What is included: the brief and role specification, market mapping, direct approach, candidate assessment, shortlist reporting, interview coordination, referencing support, offer management and contact through the start of the appointment.

For context on pay levels by function and firm type, see our SMF salary guide.

Compensation and package structure

Package design at regulated firms is shaped by remuneration rules as well as the market. The bonus cap that limited variable pay for material risk takers at banks and large investment firms was removed on 31 October 2023, and the subsequent reforms in FCA PS25/15 and PRA PS21/25 simplified the remuneration codes further, including shorter deferral periods. Firms outside the scope of those codes have more freedom, but boards still need to show that incentives for senior managers support good customer outcomes under the Consumer Duty and do not reward excessive risk-taking.

For interim and fractional SMF holders the package is a day rate rather than a salary and bonus, and the question to settle early is the commitment: how many days a month the role genuinely needs, how availability is covered between scheduled days, and how the individual will evidence the time spent if the regulator asks. For permanent hires, buying out deferred awards from a previous employer is a common negotiation point; our guide to buying out deferred compensation covers how that is usually handled.

Who we place

Our financial services clients are typically:

• Small and mid-sized FCA solo-regulated firms — investment managers, IFAs and wealth planners, insurance and credit brokers, consumer credit firms — needing a fractional or permanent SMF16 and SMF17.
• Firms applying for authorisation, or for a variation of permission, that need an approvable senior team in place before the application. See building your SMF team from scratch.
• Private equity and venture-backed financial services businesses replacing or strengthening the senior team ahead of growth, acquisition or exit.
• UK subsidiaries and branches of overseas banks, insurers and asset managers.
• Banks, building societies and insurers hiring board, executive committee and control function leaders.
• Payment and e-money institutions and fintechs hiring MLROs, compliance heads, CFOs and CEOs — where SMCR may not apply but the FCA’s scrutiny of management still does.
• Family offices and multi-family offices with regulated entities in the group.

We do not publish client names; the confidentiality of a senior search matters to both the firm and the candidates.

Looking for a financial services role? If you are a compliance professional, MLRO, CFO, CRO or other senior candidate interested in regulated-sector roles, including fractional SMF16 and SMF17 work, please register with us or browse our current opportunities.

Financial Services Executive Appointments

• FCA Regulated Firm Recruitment — All SMF-level appointments for FCA-regulated firms
• CEO of FCA-Regulated Firm — SMF1 chief executive appointments
• Chief Risk Officer Recruitment — SMF4 risk leadership and enterprise risk governance
• Head of Compliance (SMF16) — Compliance function leadership at regulated firms
• MLRO Recruitment (SMF17) — Money Laundering Reporting Officer appointments
• Fractional Compliance Officer — Part-time SMF16 and combined SMF16/17 holders for smaller firms
• Financial Services NED Recruitment — Independent non-executive appointments at regulated firms
• Family Office Executive Search — CIO, COO, Director and all family office appointments
• CISO Recruitment — Information security leadership under operational resilience rules, and DORA and NIS2 where relevant

Other ways to hire. This page covers senior search across financial services as a whole. If you already know the role, the specialist pages go further: compliance director recruitment, CCO recruitment, fractional CCO, interim CCO and fractional MLRO. For background reading, our financial services executive hiring guide walks through the hiring process from the firm’s side.

Frequently asked questions

What is financial services executive search?

It is retained search for senior leaders at banks, insurers, asset and wealth managers, brokers, lenders, payment firms and fintechs. The difference from general executive search is the regulatory layer: most senior roles at authorised firms are Senior Management Functions that need FCA or PRA approval, so candidate assessment, referencing and timing all have to account for it.

Can we hire a fractional SMF16 or SMF17?

Yes. Many smaller authorised firms appoint a fractional compliance oversight holder, a fractional MLRO, or one person approved for both. The individual needs the same FCA approval as a full-time holder and must have enough time committed to discharge the role properly. See fractional MLRO.

Can one person hold both SMF16 and SMF17?

Often, yes, particularly at smaller firms. The FCA expects the combination to be proportionate to the firm’s size and complexity and the individual to have the time and expertise for both. Larger or higher-risk firms usually separate the functions.

How long does FCA approval of a senior manager take?

FSMA gives the regulator three months to decide a complete application. The FCA’s published median for senior manager approvals in 2025/26 was about 25 days, but individual cases vary, and incomplete applications take longer.

What happens if our SMF holder leaves suddenly?

Under SUP 10C.3A.6R a firm can arrange temporary cover and has 12 weeks to submit an application for the replacement; the cover can continue until the application is decided. The FCA has proposed extending this to 18 weeks. An interim appointment is the usual way to bridge the gap.

Are payment and e-money institutions covered by SMCR?

No. Payment and e-money institutions are outside SMCR. They must appoint an MLRO under the Money Laundering Regulations, and the FCA assesses the people responsible for managing the business at authorisation, but these are not SMF approvals.

Does a CFO at an FCA firm need to be SMF2?

Only at banks, insurers and Enhanced firms. At a Core firm, a CFO who sits on the board is normally approved as an Executive Director (SMF3). A CFO who is not a board director may not hold an SMF at all.

Which senior roles are changing under the latest SMCR reforms?

CP26/37 and PRA CP14/26 propose moving several committee chair functions (SMF10–14), plus SMF5 and SMF15, from pre-approval to notification, removing SMF18 and SMF22, and raising the Enhanced firm thresholds. SMF1, SMF9, SMF16 and SMF17 stay pre-approved. Final rules are expected in 2027.

How are your fees structured?

The fee structure is agreed at briefing according to the role and format. Interim and fractional placements are charged on a day rate that includes our fee.

Do you only work in London?

No. We work with firms across the UK, from our offices in London and Cannock, and with UK branches and subsidiaries of overseas groups. Many fractional compliance roles are largely remote with regular on-site days.

Sources and Further Reading

• FCA — Senior Managers and Certification Regime overview and guidance
• Bank of England / PRA — prudential regulation and senior manager accountability standards
• FCA — Consumer Duty obligations and executive accountability requirements
• ICAEW — financial services governance and executive accountability standards
• The Investment Association — asset management industry standards and executive governance

Financial services businesses may also require: FCA Regulated Firm Recruitment | Head of Compliance | MLRO Recruitment | CRO Recruitment | CISO Recruitment | Family Office Executive Search | Financial Services NED