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HoLP, HoFA and MLRO Applicant Criteria

Pre-Application Requirements

Applicants not previously approved as a CLC HoLP/HoFA/MLRO or SRA CoLP/CoFA are required to provide evidence of the steps which they have taken to develop their legal and regulatory knowledge and skills in preparation for carrying out the role which they are applying for.

Applicants should provide evidence of having recently completed an externally assessed compliance course/training targeted at the responsibilities of the role i.e. HoLP, HoFA or MLRO.

Qualified Lawyers and Finance Professionals applying for any of these roles must also provide evidence of their past 12 months completed Ongoing Competency Activities. This includes Applicants associated to a Switch or Hive-Off Application and who are currently approved as a CoLP or CoFA. Applicants who are currently approved as a CoLP or CoFA should also provide written evidence from the SRA confirming the dates when they were approved as a COLP or COFA.

All first-time appointees should source and complete externally assessed courses covering the compliance areas specific to the role which they are applying for and provide evidence of this with their application.

All appointees should familiarise themselves with the CLC Risk Agenda and complete any necessary training and development activities to ensure that their legal and technical knowledge is up to date in the areas identified in the Risk Agenda, at a level which is appropriate to the nature and scale of the practice they are responsible for.

Minimum Levels of Occupational and Professional Experience

CLC Practices notifying us of a Change of HoLP or HoFA.

It is incumbent on the Practice to ensure that the current appointees as HoLP or HoFA remain in post and continue with their compliance supervisory responsibilities until such time a suitable replacement has been approved by the CLC. The standard time frame can be up to eight weeks. Practices should also ensure, in advance of requesting an Application Form for a New HoLP or HoFA, that for HoLP Applicants the intended appointee holds a current and valid licence free of conditions and for All Applicants they have been put on notice of the CLC’s expectation regarding eligibility and preparedness to pursue an application.

Fees in relation to HoLP/HoFA/MLRO Applications will be charged to the Practice. Please also inform us when the applicant is intended to, in addition to this role, be a Registered Manager and verify that they meet the minimum criteria to apply for the authorisation (as outlined here). This is a separate application and will incur additional fees. Additionally, it is also important to inform us as to whether the applicant is intending to hold an equity percentage or shareholding.