Consulting & Advisory

Operational Setup & Hiring for Regulated Entities

We stand up the operating model of your licensed entity and staff it with qualified, fit-and-proper people — so the business a regulator approved on paper actually runs in practice.

Overview

A licence is a permission to operate, not an operation. Supervisors increasingly look past the application file to ask a harder question: can this entity genuinely run the business it was authorised for? SKY7 builds the answer — translating your authorisation conditions and policies into a working organisation, defining the roles that must exist, and recruiting and placing the compliance, risk and operations staff who hold them. The result is a regulated entity that functions on day one, evidences real control, and withstands the first supervisory review rather than scrambling for it.

01

Organisational design and target operating model

We start from your licence scope, business plan and risk profile and design the organisation around them — not a generic template. That means a clear org structure, defined reporting lines, decision rights and segregation of duties, sized to the activity you are actually authorised to perform.

The output is a target operating model that maps every regulatory obligation and core process to an owner: who runs payments operations, who owns the AML programme, who signs off risk decisions, and how those functions interact. We right-size it to your stage, so an early-stage EMI is not carrying the headcount of a tier-one bank, while still meeting the substance and control expectations of its regulator.

02

Key function holders and governance roles

Regulators authorise people as much as entities. We identify the key function holders your regime requires — typically a head of compliance, an MLRO/AML officer, risk, finance and senior management or board roles — and define each mandate, its responsibilities, reporting line and required competencies.

For each role we prepare the supporting documentation supervisors expect: role descriptions, responsibility maps, and the fit-and-proper evidence that demonstrates the individual is competent, experienced and of good standing. Where notification or regulatory approval of an appointment is required, we structure the role and its file so it is ready for that assessment.

03

Second-line functions and the three-lines model

A credible regulated entity separates the people who run the business from the people who independently challenge it. We build the second line — compliance and risk management — as a genuinely independent function with its own mandate, escalation rights and direct access to senior management or the board.

We implement a three-lines-of-defence operating model that fits your size: clear first-line ownership of controls, an empowered second line that monitors and challenges, and a route to independent assurance. This is the structure supervisors look for as evidence of real, ongoing oversight rather than control on paper.

04

Translating policies into working operations

Most newly licensed entities hold a shelf of policies drafted for the application that no one has yet turned into daily practice. We close that gap — converting your AML, risk, safeguarding, conduct and operational policies into the procedures, controls, checklists and system configurations that staff actually use.

For each policy we define the operational steps, the control points, the records to be kept and the person accountable. The aim is a straight line from a regulatory requirement, through a written policy, to a repeatable process with an audit trail — so that what you committed to in the licence file is demonstrably happening in the business.

05

Outsourcing, providers and oversight

Few regulated entities run everything in-house, and supervisors accept that — provided outsourced and critical functions remain under genuine control. We help you decide what to build, what to outsource and what to keep close, then put the oversight framework around it.

That covers selecting and onboarding providers, structuring outsourcing arrangements with the contractual and exit terms regulators expect, classifying critical or important functions, and standing up the monitoring, KPIs and review cadence that keep accountability with your entity. Outsourcing a task is permitted; outsourcing responsibility is not — and we set the arrangement up accordingly.

06

Recruiting and placing fit-and-proper staff

The hardest part of standing up a regulated entity is usually people. We recruit and place qualified candidates across compliance, risk and operations — drawing on a network of professionals who already understand financial regulation, the relevant regime and the practical demands of a small, scrutinised firm.

We scope the role, define the competency and fit-and-proper criteria, source and assess candidates, and support the appointment through to placement — including the documentation needed for any regulatory notification or approval. Where a permanent hire is premature, we can place interim or fractional function holders so the entity is properly staffed from day one and the role is filled by someone who can credibly perform it under supervision.

How we work

We typically run the engagement in four stages. First, we frame: we read your licence conditions, business plan and existing policies and design the target operating model, the roles that must exist and the staffing plan. Second, we build: we define mandates, translate policies into procedures, structure outsourcing and oversight, and prepare the fit-and-proper documentation. Third, we staff: we recruit, assess and place the compliance, risk and operations people who hold the key functions, supporting any required regulatory notifications. Fourth, we embed and review: we make sure the functions are operating, controls are evidenced and the organisation is ready for its first supervisory review — then hand over to your team with the runbook to keep it running.

Timelines depend on the regime, the roles in scope and the local talent market, and we will give you a realistic view at the outset. We do not promise specific hiring or approval outcomes — those rest with candidates and regulators — but we structure the work so the entity is genuinely operational and the evidence of control is real.

FAQ

Frequently asked questions

When in the licensing process should we start operational setup and hiring?

Earlier than most founders expect. Many regimes require named key function holders and a credible operating model as part of the application itself, and supervisors increasingly probe substance before granting permissions. Starting operational design and recruitment in parallel with — or immediately after — the application means the entity is genuinely ready to operate when the licence is granted, rather than treating staffing as an afterthought.

Which roles do you typically help staff?

The second-line and operational roles that regulated entities must have: head of compliance, MLRO or AML officer, risk management, and operations leadership, alongside relevant senior management or board positions depending on the regime. The exact set of key function holders is driven by your licence type and jurisdiction, which we map at the framing stage.

What does fit-and-proper mean in practice, and how do you support it?

Fit-and-proper is the regulator's test that the people running key functions are competent, experienced, honest and financially sound. In practice it means matching the right individual to the role and assembling the evidence — qualifications, track record, references and good-standing checks — in the form supervisors expect. We define the criteria for each role, assess candidates against them, and prepare the documentation needed for any regulatory notification or approval.

Can you provide interim or fractional function holders rather than permanent hires?

Yes. Where a permanent appointment is premature or the right candidate needs time to source, we can place experienced interim or fractional function holders so the entity is correctly staffed from day one. This keeps the role filled by someone who can credibly perform it under supervision while you build toward a permanent team.

Can we outsource compliance and operations instead of hiring?

Some functions can be outsourced, and we help you structure those arrangements with the contracts, classification and oversight regulators expect. But responsibility cannot be outsourced — the accountability stays with your entity and its key function holders. We help you draw that line correctly, keeping critical decisions and control in-house while using providers for capacity, and putting the monitoring framework around any arrangement.

Get started

Stand up your regulated entity — and staff it properly

Start with a confidential consultation. We will review your licence scope and operating needs, identify the roles and functions you must put in place, and map a realistic plan to build and staff the entity.

Response time
Working day, every day.