Senior Management Functions – SMF16 & SMF17

Approved Persons and New Senior Manager Functions

SM&CR Replaces Controlled Functions

An “Approved Person” is an individual who is directly approved by the FCA to perform one or more activities on behalf of an authorised firm. They will continue to be approved under the new Senior Manager and Certification Regime (SM&CR).

The majority of controlled functions have automatically been converted to Senior Manager Functions (SMF) by the FCA, but it is the firm’s responsibility to ensure the individuals hold the correct SMF. See function mapping table below.

Firms with a Limited Permission – for example, motor dealers who are not directly authorised for general insurance – will normally only require one Approved Person.

When considering a candidate for approval under SM&CR, the firm must satisfy itself that a person is Fit and Proper (FIT) before applying for them to be approved as an SMF. The FCA will look at the individual’s:

  • Honesty
  • Integrity and reputation
  • Competence and capability
  • Financial soundness

Individuals can hold more than one SMF function and be an Approved Person for more than one firm so long as they are satisfied the person is FIT to undertake the role.

Previous Controlled FunctionCorresponding Senior Management Function(s)
CF1 – DirectorSMF3 – Executive Director
CF2 – Non-Executive DirectorSMF9 – Chair
CF3 – Chief Executive
SMF1 – Chief Executive
SMF19 – Head of Third Country Branch
CF4 – Partner
SMF3 – Executive Director
SMF27 – Partner
CF5 – Unincorporated AssociationSMF3 – Executive Director
CF6 – Small Friendly Society FunctionSMF3 – Executive Director
CF8 – Apportionment & oversightSMF29 – Limited Scope
CF10 – Compliance & OversightSMF16 – Compliance Oversight
CF11 – Money Laundering Reporting Officer (MLRO)SMF17 – Money Laundering Reporting Officer (MLRO)
CF29 – Significant Management FunctionSMF21 – EEA Branch Senior Management Function

Senior Managers are required to comply with the FCA’s conduct rules under SM&CR

FINCO Search – Preferred Recruitment Agency and Headhunter to the SM&CR Compliance Markets

If you are looking for a role covering SMF16 and SMF17 or other Senior Management Functions, please view our latest compliance jobs and careers.  If you are a client looking to hire an experienced SMF16 and SMF17 candidate, we can help you recruit an SMF16/SMF17 candidate here. 

If you are interested in finding out how we can assist you in finding your next opportunity in the UK or internationally then please call us now on +44 (0)203 927 5080 or register your CV online here and one of our Compliance Consultants will contact you ASAP.

If you would like to know more about some of the common terms within the Financial Markets sector than please feel free to explore our Glossary of Terms

Senior Manager Functions Positions

    • Chief Compliance Officer (CCO)
    • Head of Compliance
    • Compliance Oversight
    • Compliance Manager
    • Compliance Director
    • Compliance in Asset Management
    • Compliance in Investment Firms
    • Compliance in Derivative Brokerages
    • Compliance in Financial Markets
    • SMF16 – Compliance Oversight Function
    • SMF17 – Money Laundering Reporting Function 

These are just a few examples of positions we recruit for, other positions are available.  Our team of experienced recruitment consultants can guide and advise both clients and candidates on their next hire in the compliance space with a sound knowledge and targeted network. 

To see our latest vacancies, please click here – compliance jobs

Contact Us

We are here to help, speak to one of our experienced SMF16 SMF17 Compliance Recruitment Search Consultants now on +44 (0) 203 927 5080.


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