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BCC provides outsourced and interim compliance officers for firms regulated by the Financial Conduct Authority (FCA), including the compliance oversight senior manager function (SMF16) and compliance leads for payment, e-money and crypto firms.
Selected engagements from more than 250 licences obtained since 2013, for payment, e-money and cryptoasset firms.
Volkswagen
Payment InstitutionObtained Nexpay’s FCA Authorised Payment Institution licence.
Electronic Money InstitutionObtained Dzing Finance’s FCA Authorised Electronic Money Institution licence.
Obtained Orbital’s FCA Authorised Payment Institution licence.
The short answer
An outsourced compliance officer is an external individual who runs a regulated firm's compliance function, monitoring, board reporting and FCA relationship. Where the role is the SMF16 compliance oversight function under the Senior Managers and Certification Regime, the individual must be approved by the FCA before starting, though temporary cover of under 12 weeks is permitted under SUP 10C.3.13R.
Every FCA firm must have arrangements to comply with its obligations, and firms subject to SYSC 6.1.3R must maintain a permanent and effective compliance function with the authority, resources, expertise and access to information it needs, led by a compliance officer responsible for compliance reporting. Many firms do not need a full-time head of compliance, or cannot hire one quickly. An outsourced compliance officer fills that role on a part-time or interim basis.
The work is the same as an in-house compliance officer's: a compliance monitoring programme, regular board and committee reporting, review of financial promotions and customer communications, oversight of complaints and breaches, regulatory returns, horizon scanning and the firm's day-to-day relationship with its FCA supervisor.
Under the Senior Managers and Certification Regime (SM&CR), the compliance oversight function is senior manager function 16 (SMF16). Whether a solo-regulated firm needs an SMF16 depends on its type and permissions, as set out in SUP 10C of the Supervision manual. Where it does, the individual must be approved by the FCA under section 59 of the Financial Services and Markets Act 2000 (FSMA) before taking up the role. The FCA has three months from receipt of a complete application to decide it, under section 61 of FSMA.
The FCA does not require an SMF16 to be an employee, but it assesses whether the individual has enough time, seniority and access to perform the role at the firm, alongside any other commitments. The approved person is personally accountable under the duty of responsibility and the senior manager conduct rules, and the firm remains responsible for its own compliance. We prepare the Form A application, the statement of responsibilities and the individual for any FCA interview.
When a compliance officer leaves suddenly or is absent, SUP 10C.3.13R allows a firm to appoint someone to cover an SMF manager's temporary or reasonably unforeseen absence without FCA approval, provided the cover lasts less than 12 weeks in a consecutive 12-month period. If the arrangement will run longer, the firm must apply for approval of the replacement in good time.
Separately, if an approved SMF manager is absent for more than 12 weeks while the role is held open, SUP 10C.14 requires the firm to notify the FCA on Form D. We provide interim compliance officers who can start quickly, stabilise monitoring and reporting, and either hand over to a permanent appointee or apply for approval to continue. Planning for the 12-week limit from the first day avoids an unapproved person drifting past it.
Read FCA expectations for hiring MLROs and heads of compliance
Regulation 21 of the Money Laundering Regulations 2017 (MLRs) requires firms within scope to appoint a nominated officer, usually called the money laundering reporting officer (MLRO), and, where appropriate to the firm's size and nature, a board-level officer responsible for MLRs compliance. Under SM&CR, the MLRO is senior manager function 17 (SMF17) where that function applies.
Smaller firms often combine compliance oversight and the MLRO in one individual. That can be proportionate, but the individual must have the time and expertise for both, and the board should consider whether combining them weakens challenge in higher-risk businesses. We provide both roles, separately or together, and document the rationale for the structure chosen, so the board can show the FCA why the arrangement is proportionate to the firm's size, customers and financial crime risk.
Payment institutions and electronic money institutions (EMIs) are not generally within SM&CR, and MLR registered cryptoasset firms are not either. Their compliance lead is therefore not an SMF16, but the FCA still assesses directors and managers as fit and proper, expects a compliance function proportionate to the business and, for payment firms, has given safeguarding a named individual under CASS 15.
For these firms, an outsourced compliance officer typically runs safeguarding oversight, the monitoring programme, the monthly safeguarding return and other returns, Consumer Duty reporting and complaints oversight, alongside the MLRO. Crypto firms preparing for authorisation under the new FSMA regime will move into SM&CR, so we structure the role now so that the individual can be put forward for approval.
An outsourced compliance officer is only as good as the coverage of the compliance plan. Ours covers every area the FCA expects a compliance function to oversee, scaled to the firm's permissions, with each area assigned a testing frequency, an owner and a reporting line to the board.
Outsourcing suits newly authorised firms, firms below the scale that justifies a full-time head of compliance, firms covering a departure or long absence, and firms that need senior capacity during remediation or an FCA review. It gives access to senior experience across many firms, without the time it takes to recruit, and the cost scales with the hours the firm actually needs.
A full-time hire becomes the better choice as volumes, permissions and headcount grow, or where the FCA expects a dedicated in-house function, as with larger enhanced scope firms. Many firms use an outsourced officer first and then hire, with the outsourced officer supporting recruitment and handover. Where an FCA review, a skilled person review or a supervisory letter is already under way, see our regulatory turnaround service.
Every engagement follows the same four stages, scaled to the size of the firm and the urgency of the issue.
Assessment comes first: we review your permissions, governance, policies, management information and recent FCA correspondence against the rules that apply to you. You then receive written findings, ranked by regulatory risk, with each gap tied to the specific rule it breaches and a named owner for the fix. Remediation follows: we redraft policies and procedures, rebuild monitoring plans, correct returns and prepare board papers, and we can attend FCA meetings alongside your senior managers. Finally, ongoing support keeps the position steady after remediation, through a retained monthly review, an annual compliance monitoring programme or outsourced roles such as an outsourced or interim compliance officer, SMF16 or MLRO.
Buckingham Capital Consulting (BCC) was established in 2013 and has obtained more than 250 licences in over 60 countries for payment, e-money and crypto firms. We open global markets to payment, e-money and crypto businesses: the licences to enter, the banking to operate and the compliance to scale.
For outsourced roles, that breadth matters: a compliance officer who has seen how many firms are licensed, banked and supervised can tell a firm which issues the FCA will treat as serious and which it will not.
Because BCC also arranges banking for regulated firms, our compliance work is written with the questions banks and safeguarding providers ask in mind. A firm whose controls satisfy the FCA and its bank at the same time spends less time answering the same questions twice. To discuss your firm, use the contact form and tell us your permissions, your current team and the issue you need resolved.
Yes. Firms can appoint an external individual as compliance officer, including as SMF16 where that function applies, provided the FCA approves the individual and is satisfied they have the time, seniority and access to perform the role. The firm remains responsible for its compliance.
SUP 10C.3.13R allows a firm to appoint someone to cover a senior manager's temporary or reasonably unforeseen absence without FCA approval, if the cover lasts less than 12 weeks in a consecutive 12-month period. Longer cover needs an approval application.
Under section 61 of FSMA, the FCA must decide a complete senior manager application within three months of receiving it. Incomplete applications, requests for information and interviews can extend the overall process, so firms should apply early.
Yes, and smaller firms often combine the roles. The individual must have enough time and expertise for both, and the board should consider whether combining them reduces independent challenge, particularly in higher-risk businesses.
Payment institutions and EMIs are not generally within SM&CR, so they do not appoint an SMF16. They still need fit and proper directors and managers, a proportionate compliance function, an MLRO under the MLRs and, under CASS 15, an individual responsible for safeguarding.
Cost depends on the firm's permissions, size, risk and the time the role needs each month. BCC scopes each role after an initial assessment of the firm and confirms the arrangement in writing. Use the contact form to describe your firm.
Tell us what you need and where you operate.