Danos Group
05 Feb

Since December 2019 the Senior Managers and Certification Regime (SMCR) now affects over 47,000 UK firms governed by the Financial Conduct Authorities. Preparing for SMCR is vital, as it applies to those from very small firms (including sole traders and limited permission consumer credit firms) to some of the largest global firms within the Banking and Financial Services sectors, including all Financial Services and Markets Act authorised firms, as well as branches of non-UK firms with permission to carry out regulated activities in the UK.

The SMCR has applied to the banking sector since March 2016 and to dual-regulated insurers since December 2018. However, it replaced the Approved Persons Regime (APR) for solo-regulated firms from the 9th December 2019. It sets a new standard of personal conduct for everyone working in Financial Services.

What is the Senior Managers and Certification Regime?

The aim of the regime is to “reduce harm to consumers and strengthen market integrity by making individuals more accountable for their conduct and competence”. 

The two ways it hopes to achieve this are:

  • Encourage a culture of staff at all levels taking personal responsibility for their actions.
  • Make sure firms and staff clearly understand and can demonstrate where responsibility lies.

SMCR requirements depend on the size of the firm. Most firms will be subject to the requirements of the Core regime and smaller firms will fall into the Limited regime, while larger and more complex firms will be subject to additional requirements under the Enhanced regime.

The three SMCR categories:

  • Core: firms in this tier will have to comply with the baseline requirements.
  • Limited: this will apply to firms who already have exemptions under the Approved Persons Regime. These firms will be exempt from some baseline requirements and will typically have fewer senior management functions.
  • Enhanced: this will apply to a small number of firms whose size, complexity and potential impact on consumers or markets warrant more attention. These firms will have extra requirements.

By 9th December 2020 solo-regulated firms will need to ensure:

  • All relevant staff are trained on the Conduct Rules and how they apply to their roles.
  • All staff in certified roles are fit and proper to perform that role and are issued with a certificate.
  • They have submitted data to the FCA for the directory of key people working in financial services.

This implementation will take time and resource. The FCA is advising firms to start preparing for SMCR now, and have published some preparation information and guideless to support.

If you need some extra help to ensure you meet the deadline. Danos Consulting is experienced in implementing and preparing for SMCR and are very well-placed to support you. In particular, we can:

  • Advise on the optimisation of existing governance structures.
  • Review existing policies.
  • Advise on interpreting and applying the new rules and guidance.
  • Provide template documentation.
  • Deliver bespoke training.
  • Assess ongoing compliance needs.

One of the SMCR’s core aims is to encourage firms to embed good governance and make accountability and transparency second nature. Doing this requires instilling a compliant culture throughout your organisation. This can be achieved by ensuring you are hiring the right talent.

As a leading supplier of Compliance and Risk personnel to the Banking and Financial Services industries globally, we are extremely well-placed to find you the best permanent and interim candidates. We use our experience and market knowledge to help you land the best people for your roles. 

If you would like to find out more or would like our support or advice on permanent and interim resource solutions, please do get in touch.

Denis Spearman
Partner, Head of Compliance – Permanent Roles

Tel: +44 (0) 20 7371 8332
Email: dspearman@danosassociates.com

Katherine Lord
Associate Partner, Head of Danos Consulting – Interim Roles

Tel: + 44 (0) 207 010 1153
Email: klord@danosconsulting.com

31 Jan

Banking competition has been encouraged over the last few years, and the market has become very diverse. In the past, there was one universal banking model, but today there are many. Large challenger banks as well as the smaller challenger banks and FinTech firms with niche specialisms, now operate successfully across the market and require broader non-traditional hiring strategies for senior Compliance and Risk professionals. 

External v Internal

Heads of Compliance and Chief Risk Offices in early-stage start-ups usually need to be hired externally, typically attracting talent from one of the big five retail banks or a nationwide. This type of external hiring is also seen across both small and large challenger banks. 

Challenger banks do hire from other challenger banks, with smaller firms offering great opportunities for individuals to take on broader roles.

Whist the big five banks typically continue to leverage their internal pools of senior individuals, by moving them up into senior Compliance and Risk leadership roles. Larger challenger banks tend to have a small number of internal promotions, leveraging their team talent pools. 

Interim v Permanent

Executive interims and contractors are often hired at start-ups and smaller challenger banks, to enable them to manage their fixed costs. As these firms grow often interim executives are often offered permanent roles.

New businesses benefit from the board experience that interim executives can offer. There has been a rise in the calibre of senior Compliance and Risk professionals who have opted for short term contracts, rather than permanent roles.


Firms are actively looking to address gender diversity, as historically only a small proportion of heads of Risk and Compliance at challenger banks are female. Many firms are actively looking to hire senior female talent and are offering talent development programmes to ensure gender diversity.

The hiring of both executive interim and permanent senior Rick and Compliance roles will continue to be in demand, as firms at different stages of their lifecycle, regulatory processes and growth will require different experience.

As a leading supplier of Compliance and Risk personnel to the financial services industry globally, the Danos Group are extremely well-placed to find you the best permanent and interim candidates.

We use our experience and market knowledge to help you land the best people for your roles.  Treating each client as unique, understanding the business requirements and advising on the best hiring strategies, to ensure you have the best and most appropriately experienced talent.

If you would like to find out more or would like our support or advice on permanent and interim resource solutions, please do get in touch.

Ruaridh Brown-Hovelt
Associate Partner, Head of Risk and Quant Practice (EMEA) – Permanent roles

Tel: +44 (0) 20 3889 5757
Email: rbh@danosassociates.com

Katherine Lord
Associate Partner, Head of Danos Consulting – Interim Roles

Tel: + 44 (0) 207 010 1153
Email: klord@danosconsulting.com

31 Jan

Since the last UK general election (December 2019), the Danos Group has experienced a significant surge in recruitment activity in the UK and across Europe. The start of 2020 is noticeably busier than early 2019. Confidence across the market has improved considerably, and the Danos Group has had its busiest ever December and January.

During the last six months of 2019 Danos Associates experienced an increase in search recruitment activity, despite the continued economic instabilities. Firms did not have the staffing resources to execute their business growth plans, and they no longer let the UK’s political indecisions hold them back. From the summer we started to see a significant rise in hiring August was our leading summer month on record. This then surged post the December UK general election and the confirmation that Brexit was going to happen.

Across 2019, we saw high recruitment demands across the European financial centres including Amsterdam, Dublin, Frankfurt, and Luxembourg, coupled with the continued growth of nearshoring centres across Eastern Europe.

The second half of 2019 was our strongest period in the North American market since establishing ourselves in 2014. Over the last year, we have seen our business grow beyond that of New York City where our US headquarters is located. We are now working with clients across the US, branching further into the Los Angeles, and San Francisco markets, as well as undertaking searches in Boston, Chicago, and Greenwich.  Our networks in all these markets have grown considerably.

As the nearshoring phenomenon continues in the US, we anticipate increased activity this year, as we support our clients in relocating teams to lower-cost centres, away from more expensive traditional Financial Services hubs. Even with the nearshoring trend, our clients in New York City continue to be very active, with lots of hiring occurring.   

Our Singapore office had a very strong second half of 2019, they delivered the best performance ever, this growth and demand is set to continue in 2020. We have seen rapid growth as new FinTech companies enter the market, and we are seeing a high demand for strategic or innovative candidates. The MAS (Monetary Authority of Singapore) fully support the importance of the FinTech opportunities as highlighted by their Managing Director Mr Ravi Menon, “Singapore’s FinTech journey is about innovation, inclusion and inspiration. Everything we do in FinTech must always have a larger purpose – to improve the lives of individuals, to build a more dynamic economy, to promote a more inclusive society”.

Despite Hong Kong being immersed in anti-government protests for months, there are opportunities, and it was recently reported by the Asia Securities Industry and Financial Markets Association, that the Hong Kong capital markets remain an important gateway between China and the world. Last year in the months of November and December our clients were hiring actively, and we continue to experience a good level of search activity in this market.

Danos Consulting had its best year ever in 2019, with demand concentrated predominantly across buy-side, FinTech and the medium-sized banking groups. 2020 brings a certain degree of transition due to the upcoming legislation, and the larger banking groups blanket approach of putting all interim/consultants inside IR35. Those firms taking a case-by-case approach are managing to secure some of the best shorter-term staffing solutions available. We expect the market to remain solid through the early part of 2020 and then pick-up rapidly post the IR35 implementation hiatus.

Whilst it is certain that we will continue to experience local and global challenges, our specialist teams will stay close to our clients and their markets, ensuring that we understand the ever-changing environment that they operate within. Whether it is the changes in regulation or the political landscape, we will continue to find innovative solutions to ensure our clients have the best talent in place to support and grow their businesses.  

If you would like to discuss your hiring strategies or consulting projects, then please do get in contact.

Dominic Danos
Global Managing Partner

14 Jan

As a global headhunting firm that specialises in Compliance, Legal, and Risk within the Banking and Financial Services Industry, we had a busy 2019 adapting to new and developing trends within the sector, around the globe.  From the growth of teams across Europe in anticipation of ‘Brexit’ to the expansion of the Singapore market, and the changing geography of Compliance within the US – 2019 has been a year of change. 

The regulatory landscape is an ever-changing beast, and in our experience, reacts (or proacts) to various trends, including profitability of business lines, business lines that are in trouble, the economy, socio-political events, and so on.     

Hiring in this space naturally reacts to the needs created by these trends, so we constantly get asked “what is going to happen with hiring in 2020?” by our clients and candidates. We can formulate an opinion, gleaned from hundreds of conversations with practitioners every week, and are able to give a coherent view.  

US Compliance Market Trends

As far as the US Compliance ‘market’ is concerned, in 2019 we saw new and developing trends that have required creative, and expert headhunting skills to find the right people for our clients. 


The ‘near-shoring’ phenomenon is happening in most ‘tier one’ Global Banking and Markets institutions.  The practice of relocating teams to lower-cost centres, away from more expensive traditional financial services hubs, is in full-throttle.  In 2019 we supported many clients with their hiring in these new hubs; in fact, this activity is at the highest level we have seen since launching Danos Associates US back in 2014.

There is much ‘academic’ debate around the long-term wisdom of this practice, but most big firms are doing it.  Near-shore / low-cost / high-value centres are growing all over the US. While this creates opportunities and economic growth in these new near-shore hubs and makes short-term economic sense to firms engaging in the practice, the other side of the coin sees jobs moving away from traditional financial services centres like New York City, and presents future hiring problems in the new hubs where experienced talent is less abundant.

As a result, more candidates are open to relocation, considering opportunities in a different sector within the industry, or moving to a non-peer firm. 

While the ‘tier one’ investment banks are all doing this to varying degrees, second and third-tier firms are very active in hiring in the traditional hubs.  We see constant migration of talent away from the tier one firms into this space, which can present great opportunity and exposure for candidates used to a bigger firm environment.  


Compliance hiring within buy-side firms has been very active in the last 12-24 months. The big players continue to build out investment bank style compliance structures, and therefore attract much talent from the sell-side.  Also, with many firms developing new products and strategies, there has been a constant demand for strong Compliance and Legal personnel to support those business lines. 

The Private Equity space has been particularly active in 2019, we placed multiple candidates with Private Equity clients in New York, Chicago, San Francisco, and Washington DC. 

Anti-Financial Crime

Anti-Financial Crime Compliance has been in particular growth over the last year and we saw continued demand for strong candidates across Sanctions, Financial Investigations, Trade Surveillance, Anti Money Laundering, KYC & Enhanced Due Diligence, etc. and across various US locations, including New York, Chicago, Houston, and Dallas. 

This will undoubtedly be a major growth space within Compliance in 2020, as the trend of pushing into new business lines that have higher financial crime risk attached continues.  While for many firms, this means the broader consumer banking space, there is still much hiring activity for financial crime talent within institutional client focussed businesses.   

Consumer Banking

Many of our global banking group clients have been pushing more into consumer banking and away from the previously hot institutional space.  Whether it be via digital banking and lending, mortgages, or cards, there has been a clear push in this direction for many firms who have not focussed so much on those spaces before. 

This obviously creates more opportunities for Legal & Compliance practitioners in the consumer banking and cards industries, with many big firms building out a presence in various locations across the country, which echoes the near-shoring trend discussed above.

During 2019 we started working with multiple new client firms across the US, branching further into the San Francisco, and Los Angeles markets, as well as undertaking numerous searches in Chicago, Boston, Houston, and Greenwich.  Our networks in all these markets have grown exponentially. That said, New York City, where Danos Associates US is headquartered, continues to be very active, with lots of recruitment happening (despite the near-shoring).  

We would like to thank our new clients for some exciting and interesting projects, you made 2019 very interesting for us.  And of course, our longer-tenured clients are very important to us, and we thank you for your continued partnership.  

Going into a new decade and 2020, we feel very well-placed to help with Compliance and Legal hiring, across all the major hubs in the United States.  We very much look forward to our continued work in the US market and partnerships with some incredible clients and candidates. 

As a leading supplier of Compliance and Legal personnel to the global Banking and Financial Services Industry, we are extremely well-placed to find you the best-matched candidates. We have a strong track record in Compliance and Legal recruitment from Associate level to Managing Director. Please contact us to discuss this further or to ask any questions about the changing landscape.

10 Jan

Risk Management within the Financial Services has changed significantly over the last decade, and this has largely been driven by regulations that emerged after the global financial crisis, and technology advancements. It is an ever-changing landscape, requiring institutions to be dynamic in order to respond to these changes. This is where agile risk management comes in.

A recent report highlighted areas that institutions must consider when managing risk dynamically, and Danos Consulting demonstrates how Consultants and Interim Contractors can provide agile risk management solutions and skills to enable institutions to be more dynamic and capable of responding to new developments.

ONE – Increase efficiency and effectiveness of risk management by early adoption of emerging technologies: We have placed expert Consultants into the Cyber Security and Operational Risk space where technology is the key focus.

Two – Build customers trust by ensuring governance and management of employees conduct and culture: We have multiple Conduct Risk Consultants working on-site at clients that can help promote customer trust and a ‘treating customers fairly’ approach.

Three – Increase focus on strategic risks like geopolitical, FinTech and other NTC’s; and improved detection and management of these risks: We have Consultants and Interim Contractors with a variety or Risk and Regulatory skill sets that can run keywork streams or cover business-as-usual support.

Four – Transforming the three lines of defence framework by enhancing business unit responsibility for managing risks and clarifying second line of defence activities: We have strong Operational Risk and Compliance Consultants that can implement new frameworks and business models to reduce your risk.

Five – Strategically manage capital and liquidity by enhancing governance structures and improving the risk culture: We have Risk Consultants that can review your ILAAP and ICAAP and advise on best practice.

As a leading supplier of risk personnel to the financial services industry globally, we are extremely well-placed to find you the best Consultants or Interim Contractors to support your strategies. We use our experience and market knowledge to help you land the best people for your projects.  

If you would like to find out more or would like our support, or advice on our Consulting solutions, please do get in touch.

09 Jan

January 10th, for many people, will be just another Friday. That is unless you work with Crypto-assets. On this day the Fifth Money Laundering Directive (5MLD) will come into force. It will address several weaknesses in the European Union’s Anti-Money Laundering and Countering Financing of Terrorism (AML/CFT) regulations that have come to light since the enactment of the Fourth Money Laundering Directive (4MLD) back in June 2017.

For those working in Crypto-assets, this is the beginning of regulating virtual currencies including cryptocurrency.  

If your business engages with any of the following Crypto-asset activities, then this new regulation will apply to you.

  • Crypto-asset exchange provider
  • Crypto-asset Automated Teller Machine (ATM)
  • Custodian Wallet Providers
  • Peer to Peer Providers
  • Issuers of new Crypto-assets, e.g. Initial Coin Offering (ICO) or Initial Exchange Offering (IEO)
  • Publication of open-source software, e.g. Non-Custodian Wallet providers

Do you have the right regulation experts in place?

In the last decade, Crypto-assets have grown exponentially. This has meant that demand is high for quality candidates, and demand has outweighed supply. We have a bench of quality consultants that can help you fill any hiring gaps.

Do you have the resources to ensure you meet the key dates for 5MLD implementation?

  • 10th January 2020 – Deadline for beneficial ownership to be set up for corporates
  • 10th March 2020 – Deadline for beneficial ownership to be set up for trusts
  • 10th September 2020 – Deadline for centralised automated mechanisms to be set up to allow identification of those who hold or control payment accounts and bank accounts

Danos Consulting can ensure that you meet these key dates, and certify that your business delivers and exceeds regulatory expectations. As a leading supplier of regulatory personnel to the financial services industry globally, we are extremely well-placed to find you the best consultants and interim candidates. We use our experience and market knowledge to help you land the best people for your roles.

If you would like to find out more or would like our support, or advice on permanent and interim resource solutions, please do get in touch.