New and growing firms
Senior compliance leadership, without the full-time hire.
A fractional CCO who has held SMF 16 and SMF 17 and run compliance at Citadel Securities, IMC and Engineers Gate — structured the way the FCA expects.
- Who it’s for
- Spin-outs, early-stage managers, and firms where a founder or COO holds the compliance badge today
- Capacity
- Deliberately limited, and assessed firm by firm
- How we engage
- Part-time employment for the badge, with a services contract for the wider build
Three ways to structure it
Which one fits depends on where your firm is, and it can change as you grow.
James holds the badge
Named on your FCA register as SMF 16/17, under a part-time employment contract — sometimes alongside a wider COO or general counsel role.
Your person holds it
Your director, COO or compliance hire holds the badge. We build and run the framework behind them on a services contract, with independent challenge.
Both, then hand over
James holds the badge while we build the function around him, then helps hire your own SMF holder and hands over once they’re ready.
What the FCA tests
Read the full article →Test 1
Capacity
Enough uncommitted time, given everything else held, for this firm’s size and risk.
Test 2
Conflicts
Any other role — internal or external — and the conflicts it creates.
Test 3
Substance
A genuinely accountable individual making decisions, not external support alone.
Questions firms ask
Does the FCA accept a part-time SMF 16 or SMF 17?
Sometimes. Its guidance says smaller firms may propose a part-time holder, but the commitment must be proportionate and sufficient for the firm’s size, complexity and risk. The FCA tests capacity, conflicts and whether there is real substance behind the appointment.
Why does James need to be an employee to hold the badge?
The FCA expects the person holding SMF 16/17 to be a senior leader inside the business, not an outsourced provider. So where James holds it directly, it is structured as a part-time employment relationship. Where your own person holds it, we work on a normal services contract.
Why is capacity limited?
How many SMF mandates one person can hold responsibly depends on the size and risk of every firm they cover. We keep the number deliberately small and reassess it firm by firm.
Considering a fractional CCO?
A short call will show whether a fractional model fits your firm’s size and risk, and what capacity looks like in practice.