Of the multi-jurisdiction licensing programmes I have watched up close in the last four years, the ones that closed on schedule had a CCO in place before the first application was filed. The ones that did not are still, mostly, in motion.
I want to argue that this is not coincidence and not selection bias. It is a sequencing point that most hiring boards get wrong because they treat the CCO hire as a consequence of the licensing programme rather than as an input to it.
What 'in place' actually means
I do not mean signed and seated. I mean offered, accepted, and contributing to the application package while serving notice. A CCO who arrives the week the FCA returns its first set of follow-up questions has missed the part of the work that mattered: the part where the application gets framed.
Framing the application is the single highest-leverage thing a CCO does in their first six months. It includes which entity files, in what order, with what holdco structure, with what overlap of governance personnel, with what initial scope. Every one of those choices is reversible only by re-filing. None of them are reversible cheaply.
Why the modal sequencing is wrong
The board sees it as: secure outside counsel, prepare draft, file, wait, then hire the CCO who will manage the day-to-day from authorisation onwards. The counsel is then asked to draft choices the future CCO will inherit. The counsel does its best. The CCO arrives, reads the file, and either accepts choices they would not have made or, more commonly, asks to withdraw and refile. Withdraw-and-refile is a six-month cost. We have watched it happen more than once in the last two years.
“Counsel makes choices the future CCO will inherit. The CCO arrives, reads the file, and asks to refile. That is a six-month cost.”
How the candidate pool changes
Hiring before filing materially changes who you can attract. A senior CCO joining pre-application is joining to design the regulatory architecture. That is a five-year job and a credible career move. A CCO joining post-authorisation is joining to operate someone else's design. That is a steady-state job, usually paid less, and the candidate pool is narrower and more junior.
Founders running this sequence the wrong way around often find that the best candidate they could have hired six months earlier is now unreachable, because they have already taken a similar pre-application seat at a competitor. The market is not large. Every six months of delay closes the bench by about a third.
What the right brief looks like
A brief that opens before the application is filed should describe four things specifically: which jurisdictions are anticipated and in what order; what the founder will not compromise on commercially; what timeline is being committed to in front of investors; and which existing executive will be the CCO's first peer relationship. The fourth is the one most often missed. The seat does not function without a strong working line into either the COO or the CEO depending on the firm's shape.
A practical sequence
If the licensing programme begins in Q3 of a calendar year, the CCO brief should open the previous Q4. That is not aggressive. That is the realistic timeline for finding, interviewing, offering, and clearing notice on a senior compliance executive whose current employer has every reason to retain them. Boards that give us nine months produce better shortlists than boards that give us three, every time, and the candidates they hire deliver the application twelve to twenty-four weeks faster on average.
The decision the board is actually making
The board is choosing between two costs: the cost of a senior salary nine months earlier than it strictly needs to start, or the cost of a six-month delay on the licensing programme. The former is, in every case I have run the numbers on, smaller. Boards that have raised against a licensing milestone tend not to see that until they have watched a peer firm get a different result.
