5 Signs You Need a
Fractional Compliance Officer

The FCA authorisation process requires demonstrating robust compliance arrangements from day one. This includes compliance policies, monitoring programmes, risk assessments, and often a named SMF16 (Compliance Oversight) or SMF17 (MLRO) holder.

Why a fractional compliance officer helps:

• Drafts application materials to FCA standards
• Develops the compliance framework the FCA expects to see
• Can be named as proposed SMF16/SMF17—often with faster approval due to existing FCA history
• Manages FCA queries and interview preparation
• Costs significantly less than hiring full-time before you're generating revenue

When your compliance officer resigns, you face several urgent challenges:

• FCA notification: You must notify the FCA of SMF vacancies and may need to identify an interim holder
• Regulatory gap: The FCA expects continuous compliance oversight—gaps create risk
• Knowledge loss: Departing officers take institutional knowledge with them
• Recruitment timeline: Hiring a permanent replacement takes 3-6 months

Why a fractional compliance officer helps:

• Can start within 1-2 weeks—faster than any permanent hire
• Provides immediate SMF cover if already FCA-approved
• Maintains regulatory relationships and compliance programme
• Can transition to permanent fractional arrangement or hand over to permanent hire

Rapid business growth creates compliance pressure:

• New products launching faster than compliance review can keep pace
• Expanding into new markets or customer segments with different regulatory requirements
• Growing teams without adequate compliance training
• Increasing transaction volumes straining AML monitoring
• Board pressure to move fast conflicting with compliance caution

Why a fractional compliance officer helps:

• Adds senior compliance capacity without full-time commitment
• Brings experience scaling compliance from previous high-growth environments
• Can increase days temporarily during high-growth phases
• Provides strategic input on compliance-friendly growth
• Costs less than an additional full-time hire while you assess long-term needs

Regulatory issues demand immediate, expert attention:

• FCA supervisory feedback: Criticism that requires documented remediation
• s166 skilled person review: Independent review of compliance arrangements
• Enforcement investigation: FCA enforcement action or investigation
• Customer complaints: Patterns suggesting systemic compliance issues
• Internal audit findings: Significant compliance gaps identified internally

Why a fractional compliance officer helps:

• Brings independent, experienced perspective the FCA respects
• Has handled similar regulatory situations at other firms
• Can lead remediation programmes and evidence improvements
• Provides credibility in regulatory discussions
• Faster to deploy than a permanent hire during crisis

Some compliance challenges require specialist expertise:

• Consumer Duty: The FCA's new outcomes-focused regulation requires cultural and operational change
• Crypto/Digital Assets: FCA registration and the Travel Rule need crypto-specific AML expertise
• CASS (Client Assets): Client money and assets rules are complex and high-risk
• Operational Resilience: New FCA requirements on business continuity and third-party risk
• MiFID II/COBS: Investment business conduct requirements

Why a fractional compliance officer helps:

• Access specialists without hiring full-time in a niche area
• Fractional professionals often have cross-firm experience implementing these requirements
• Project-based engagement for implementation, ongoing for monitoring
• Transfer knowledge to your team during engagement