Understanding the SMF16 dimension
Defining the scope before going to market
One of the most common mistakes in compliance recruitment for asset management is going to market before the role is properly defined. In smaller managers, the Head of Compliance will often carry SMF16 alongside SMF17 (MLRO) and sometimes elements of risk oversight. This multi-hatting arrangement is understandable at an early stage of growth, yet it requires careful thought. A candidate who is genuinely capable of fulfilling multiple senior management functions independently, and comfortable with the personal accountability each carries, is a specific profile. Conflating the roles without acknowledging the demands of each tends to narrow the field of strong candidates and occasionally produces misaligned hires.
For boutique or emerging managers preparing for FCA supervision or seeking institutional capital, it is worth being clear about whether you need a compliance professional who can build a framework from scratch, or one who can embed into an existing structure and improve it. These require different backgrounds and different motivational profiles.
What to look for beyond technical knowledge
The best Heads of Compliance in asset management combine deep technical knowledge of the FCA Handbook, including COBS, SYSC, AIFMD, and increasingly Consumer Duty, with genuine commercial awareness. They understand how the business generates revenue, what the investment strategy involves, and how to frame compliance guidance in terms that portfolio managers and senior leadership will act on rather than work around. A candidate who communicates only in regulatory language, without connecting it to business consequences, tends to have limited influence in practice.
Experienced professionals in this field are also evaluating the employer carefully. They will look at the culture of the firm, the quality of existing governance, and whether senior leadership treats compliance as a genuine function or a box-ticking exercise. Firms that are transparent about their current position, including any areas under development, attract stronger candidates than those who present an unrealistically polished picture.
Timing and approach
The timing of a Head of Compliance hire matters more than many firms appreciate. Bringing in a strong SMF16 ahead of a period of growth, a strategy expansion, or a regulatory review gives the incoming individual time to understand the business and make considered improvements. Hiring reactively, in response to a departure or a regulatory concern, places the new hire under immediate pressure and limits their effectiveness considerably.
For firms with senior compliance needs, a retained or proactive executive search approach, rather than advertising alone, is typically the more effective route. Most experienced compliance professionals at this level are not actively searching job boards. They are identifiable, approachable, and assessable through a focused market search by a recruiter with genuine knowledge of the compliance talent pool in asset management.
About Fram Search
Fram’s Corporate Functions Practice provides a deeply consultative recruitment service focusing on Finance & Accounting, Legal & Compliance, and Operations functions.
Established in 2010, Fram Search is a specialist financial services recruitment consultancy. We focus on mid-to-senior hires in the UK and internationally, providing high quality contingent and retained recruitment services, focusing on permanent & interim placements at all levels.
We have long established relationships, outstanding market knowledge, and access to deep talent pools. Fram takes a highly consultative approach, combining outstanding tech with a human approach. We are proud that our contingent fill rate is nearly three times the industry average and we augment our retained search methodology with rigorous psychometric testing. We take ESG seriously, we are champions of diversity and all staff have undertaken unconscious bias training. We also carbon offset.
Please contact us on 01525 864 372 / [email protected] to learn more.
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