The Senior Managers and Certification Regime continues to be a priority for the FCA. For smaller asset managers, especially those with 10 to 50 staff, the challenge is often not understanding the rules but resourcing them effectively. Many firms still rely on one individual to hold both SMF16 and SMF17 responsibilities. While this can seem efficient, it creates pressure points and increases the risk of oversight gaps, particularly when the role holder is managing a wide range of other compliance and operational duties.

This is not legal advice. It is market guidance based on what we see when working with clients across the buy-side. Firms should always seek professional advice when considering changes to their SMCR framework or senior manager allocations.

When the same person is responsible for compliance oversight and money laundering reporting, the workload can become disproportionate, especially during periods of regulatory change, thematic reviews, or internal projects. SMCR is designed to make accountability clear, but in smaller firms that clarity can become concentration. Holidays, sickness, or unplanned absences can leave the business without active coverage of critical functions. This not only creates operational risk but can also place strain on governance if board and committee meetings are delayed or if reporting deadlines are missed. For the individual concerned, it can mean a constant juggling act between tactical firefighting and strategic planning, with the risk that neither gets the attention it deserves.

The decision to bring in additional senior compliance leadership, or to restructure responsibilities, is often about more than simply reducing workload. It can be a strategic move to strengthen resilience, improve challenge at board level, and free the existing SMF16 or SMF17 to focus on forward-

looking compliance planning rather than being drawn into day-to-day operational detail. In some cases, firms choose to hire a dedicated deputy who can act as cover and support. In others, they split SMF16 and SMF17 across two individuals to ensure that each role holder can give full attention to their specific responsibilities. There is no single model that works for every asset manager, but there is a clear benefit in having contingency built into the structure.

At Fram Search, we regularly speak with asset managers about their SMCR arrangements and the options available when resourcing SMF16 or SMF17 roles. In some cases this involves recruiting a new senior compliance professional to take on full accountability. In others it means identifying leaders who can operate effectively within smaller teams and adapt to a broad remit. We also see firms considering fixed-term solutions, where an interim appointment can provide stability during periods of change. This can be particularly useful when a long-serving compliance head steps down or during the lead-up to an FCA visit, allowing time to make a permanent appointment without leaving a gap in coverage.

The market for experienced SMF16 and SMF17 candidates is tight. Many are already in stable positions with significant influence in their current firms. Convincing them to consider a move requires more than a competitive salary. It involves positioning the role as one where the compliance function is genuinely valued, where they will have a seat at the leadership table, and where they can make a meaningful impact. Cultural fit is critical. In a smaller firm, a new senior compliance hire will interact daily with senior portfolio managers, operations teams, and sometimes clients. The ability to work collaboratively, while maintaining independence of thought and action, can be the difference between a successful appointment and one that fails to gain traction.

Strengthening SMCR oversight is not about adding layers of bureaucracy. It is about ensuring that the firm can maintain high standards of governance and compliance without stretching individuals beyond a sustainable level. For smaller asset managers, that may mean making the decision to hire

SMF16 SMF17 asset management talent sooner rather than later. The right appointment can protect the business, reassure the regulator, and create capacity for the leadership team to focus on growth.

If you are reviewing your SMCR arrangements and want to explore your options for an SMCR compliance hire asset manager role, we would be pleased to have a confidential discussion about the talent available and how to secure it.