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FCA MLRO (SMF17) & Compliance Officer (SMF 16) Requirements 2022

In Early 2022, the FCA laid out its thoughts on what companies need to be considering when wanting to make these essential compliance appointments in their blog post .

These are still relevant in 2024

Companies are reminded that individuals appointed to these functions ought to be both sufficiently experienced as well as with the ability and competency of properly performing them. For this reason, firms need to give cautious consideration to just how their SMF16 and also SMF17 prospects can totally demonstrate these attributes.

The FCA has actually shared some instances which lay out what, in its experience, tends to aid in the successful approval for both of these functions.


Compliance Officer & MLRO – Training

The majority of successful candidates will certainly have “finished relevant training courses prior to using […] for authorisation.” On the other hand, those “who plan to finish needed courses after approval” are less likely to be approved. Particularly, applicants are anticipated to have:

  1. Attended training programs customised or pertinent to the kind of business the company they propose to work for.

  2. Participated in current as well as up-to-date training to provide relevant expertise of the present regulatory regulations and assumptions.

  3. If training has actually not been completed lately, the FCA may ask if the candidate has supplemented their training with recent continuous professional growth (CPD) training courses.

  4. Attended training programs with enough length as well as depth to obtain expertise to carry out the function.

Below, the regulator keeps in mind that “Really brief ” ‘initial’ training courses, alone, do not provide sufficient coverage or depth to be beneficial for a head of conformity or MLRO, even in the smallest firms.”
Whilst the FCA does not endorse or list details of preferred training courses or training providers, it explains that training courses with an assessment or evaluation element have a tendency to much better demonstrate that an applicant has onboared a relevant and sound understanding.

Experience Required for SMF16 and SMF17

Individuals from varied expert histories as well as varying degrees of seniority can capably function as heads of compliance or MLROs. Straight previous experience in these duties is not needed for an effective application, neither is it an assurance of automatic FCA approval. The regulator notes that:

  • Successful applicants might have held more jr compliance functions in the past, such as compliance manager or replacement MLRO.

  • Previously holding the exact same or comparable approved settings is a great demonstration that somebody may be suitable for these roles however does not indicate an applicant will be automatically approved.

  • Effective applications for SMF16 as well as MLROs have a range of histories and experience, including in compliance as well as legal groups, legal representatives, accounting professionals, and as specialists.

Nevertheless, the FCA notes: “The experience of a candidate who has just formerly operated in a front-line role (and in the absence of other training or experience) is usually inadequate to show that they have the required skills as well as expertise to establish and also operate a compliance function.”


The FCA likewise approves that “it might be appropriate and also proportional” for proprietors or chief executives of little firms to double up as the firm’s head of compliance or MLRO. That said, they “still expect those people to have appropriate training and experience to ensure their company will follow the relevant guidelines and regulations for their company.”


Compliance Consultant Assistance
The FCA acknowledges that candidate firms may have differing degrees of exterior regulatory compliance support; exterior advisors like compliance consultants can assist with both FCA applications and the continuous running of a company’s regulatory demands. Whilst it is not a requirement, the regulator keeps in mind that such a setup “may be an useful addition and supplement to the company’s very own in-house setups.


All of our Compliance Consultants have a minimum of 5 years in a senior management position and are qualified to at least level 4 (Chartered) status or equivalent; many have more. We can provide someone to help set up the Compliance and AML framework, but it is always best to have an internal senior manager/director as the appointed SMF once authorised.


With or without exterior assistance, the person that will certainly be accountable for the compliance and/or MLRO functions will require to demonstrate that they have “sufficient understanding and experience themselves to make appropriate compliance choices for the business.”


The FCA anticipates that, whether the duty is carried out full-time or part-time, the time allotted to the function needs to be “in proportion and also enough”. Additionally, where the appointees for these roles might have another role internally or externally, the FCA will look very closely at potential conflicts of interest. One more area based on scrutiny is the physical area of the head of compliance and/or MLRO applicant. Further, the FCA state that “Successful applicants tend to be those functioning from the firm’s primary place of business in the UK.”


Ultimately, having taken account of every one of the above, also where a company is confident that their selected candidates have adequate experience and also training, the regulatory authority may still request a meeting to check this as well as to analyse relevant competency and also capability.


Below is a list of possible compliance & MLRO training companies that will provide courses for you.


FCA Compliance & MLRO Courses – resources for you.

Course providers

This page lists course providers who have at some time provided courses on money laundering and may provide similar courses in the future. Inclusion in this list does not constitute a recommendation. We have no affiliation with any of the companies.


#Recomended# Chartered Institute of Securities & Investments (CISI) 

Compliance & Risk Qualifications Pathway
Follow a progressive study route consistent with career paths in the financial services sector. New entrants to the professional field choose to start with Fundamentals of Financial Services or the Foundation Qualification – Introduction to Investment, before choosing a technical subject or considering the Investment Operations Certificate (IOC) and then continuing on to pursue our higher level specialist qualification, the Diploma in Investment Compliance.

Skillcast is the leading supplier of compliance e-learning to the UK financial services sector.

We offer the most comprehensive library of e-learning courses addressing Financial Conduct Authority (FCA) regulations.

Our library provides 60+ training modules covering everything from high-level and conduct of business standards to thematic topics, including treating customers fairly.

This course covers two areas, firstly the concept of Treating Customers Fairly, and its 6 consumer outcomes, and secondly, the Financial Sanctions that can be imposed in the UK.

FCA Compliance Training
Our FCA compliance training is designed to raise standards and levels of conduct throughout your organisation, giving you both peace of mind and the competitive edge when it comes to earning consumers’ trust.


Get CAMS Certified

CAMS (Certified Anti-Money Laundering Specialist) is the global gold standard in AML certifications, with more than 40,000 CAMS graduates worldwide. We offer self-study and enhanced learning packages to get you qualified in as little as three months. CAMS is currently available in 12 languages, including Spanish.

CCL Academy prides itself on being able to offer training on every aspect of compliance to every function of your business. Whether you require general compliance awareness training for your front/back-office staff; skills-based training for your Compliance/FCC team or focused briefings for your senior management, we can help

Keeping your firm’s AML training up to date is your legal duty. Money laundering regulations require every MLRO to have role-specific training, and set out the MLRO’s responsibility to manage the AML training of all employees.

New starter or experienced professional learning about new legislation, our online AML training is designed for everyone who needs to go from zero to knowledgeable quickly.

With saved tests at the end of each training module, you can easily show your AML Supervisor that every employee has the anti-money laundering training they need to stay compliant with the latest rules and regulations, dependent on their level.

BPP provides a range of courses on accounting, law and tax including CPD and PD courses on money laundering.

Compliance Training Products (CTP)
Anti-Money Laundering & Terrorist Financing
Anti-Money Laundering training for UK and offshore financial service providers, solicitors, accountants and estate agents

Croner-i Professional Development
Croner-i provides post-qualification training for the tax, audit and accounting professional in partnership with the Institute of Chartered Accountans for England & Wales (ICAEW). Information about courses and webinars on the money laundering regulations can be found through their website.

HAT Group
The HAT Group is a consortium providing compliance, training and recruitment services to accountancy firms. The website includes information on their latest anti-money laundering courses.

ICSA Training
Information on courses and seminars from ICSA which have previously included Money Laundering and the Proceeds of Crime Act.

Institute of Money Laundering Prevention Officers (IMLPO)
The IMLPO was established in 2001 as a broad, cross-representative forum of anti-money laundering practitioners who share views and experiences of the day-to-day business of combating money laundering. One of the IMLPO’s aims is to “facilitate the further education and professional development of members”. The IMLPO provides training workshops and seminars on money laundering.

International Compliance Association
The International Compliance Association provides a range of courses and qualifications in anti-money laundering awareness. The courses offered by the International Compliance Association were originally developed with the British Bankers Association and the University of Manchester Business School.

Information on training and specialist CPD courses provided by Mercia Group, including details of their Money Laundering Update courses.

MBL Seminars
Professional training provider for accountants, lawyers and other business professionals. The company offers CPD seminars, webinars and in-house training on money laundering and other topics.

International Compliance Association
The International Compliance Association provides a range of courses and qualifications in anti-money laundering awareness across the world.

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