Risk and compliance · ADGM and the UAE

Fractional compliance appointments for ADGM and UAE-regulated firms

Senior MLROs, Compliance Officers and risk leaders for firms in Abu Dhabi Global Market and across the UAE, from FSRA application through ongoing supervision.

5Regulators
7Roles
OngoingFractional cover
A senior compliance executive by the window of a bright Abu Dhabi office overlooking Al Maryah Island
Proven leadership

Our compliance leaders have held the line at

Emirates NBD
Mashreq
HSBC
Standard Chartered
DIFC
ADGM
PwC
KPMG
By regulator

Where are you regulated?

Firms search by where they are regulated first and by role second. Each regulator uses its own approval term, and so do we.

Financial district towers in the UAE in soft morning light

ADGM

FSRA · Abu Dhabi Global Market

Approved Person holding a Controlled Function. A Compliance Officer and an MLRO approved as Controlled Functions, a deputy MLRO and a documented risk framework.

Asset managers, brokers, advisers, banks and virtual asset firms.

CBUAE

UAE onshore financial services

Compliance Officer at management level. Under federal AML rules, a Compliance Officer at management level; banks also need CBUAE no-objection for senior compliance and risk appointments.

Payment service providers, exchange houses and finance companies.

CMA

UAE onshore capital markets

CMA-approved job holder. A Compliance Officer approved by the CMA, and AML oversight.

Brokers, fund managers and investment advisers.

DIFC

DFSA · Dubai International Financial Centre

Authorised Individual holding a Licensed Function. A Compliance Officer and an MLRO approved as Licensed Functions, a deputy MLRO, and oversight proportionate to the firm.

Wealth and asset managers, advisers, fintech and insurance intermediaries.

VARA

Dubai virtual assets (outside DIFC)

Compliance Officer approved by VARA as fit and proper. A full-time Compliance Officer and a fit and proper MLRO, which VARA allows to be outsourced, plus a risk management function.

Exchanges, brokers, custodians and token issuers (VASPs).

Appointments to roles requiring regulatory approval are subject to the relevant authority's requirements.

A senior compliance leader walking through a bright, stone-lined office
Which role do you need?

Seven roles, one accountable appointment

We start with why the role is needed, then recommend the appointment your risk profile requires, not a default one.

Every role asks for the same two things: relevant tenure and relevant experience for the role, sector and jurisdiction. Certifications and prior regulatory approval are welcome, not required; detailed screening happens in person.

  1. Regulator-approved

    Fractional Money Laundering Reporting Officer (MLRO)

    A senior MLRO, named on your licence and accountable from day one

    Your MLRO carries personal accountability to the regulator. We place experienced fractional MLROs who own your AML/CFT framework, file SARs and STRs via goAML, and act as your point of contact with the regulator and the UAE Financial Intelligence Unit.

  2. Required in DIFC, ADGM

    Fractional Deputy MLRO

    AML oversight that does not stop when your MLRO is away

    Regulators expect AML oversight to continue when the MLRO is absent. A fractional Deputy MLRO provides that continuity, supports the day-to-day AML workload and steps up to the full role when needed.

  3. Regulator-approved

    Fractional Compliance Officer

    A senior Compliance Officer, without a full-time hire

    A fractional Compliance Officer runs your compliance monitoring programme, applies policy, keeps the records regulators expect and submits your regulatory returns, so oversight stays proportionate to your risk.

  4. Usually approved

    Fractional Head of Compliance

    Senior compliance leadership where the stakes are higher

    Complex business models and higher-risk client books need one leader who owns the whole framework. A fractional Head of Compliance holds that accountability, handles escalations, oversees the MLRO and Compliance Officer, and represents the firm to the regulator.

  5. Depends on regulator

    Fractional Chief Risk Officer (Head of Risk)

    Risk governance your board and regulator can rely on

    Regulators expect a documented view of risk long before operations begin. A fractional Chief Risk Officer assesses and rates your risk, sets the appetite the board signs off, and keeps it current through periodic review.

  6. Not usually approved

    Fractional Head of Financial Crime

    Financial crime compliance, led by people who have run it at scale

    Financial crime risk sits at the centre of every UAE licence. A fractional Head of Financial Crime tests that your AML/CFT, sanctions and fraud controls work in practice, not only on paper.

  7. Not usually approved

    Fractional Head of Ethics and Integrity

    Ethics and integrity, owned at senior level

    Integrity failures rarely start as headlines. A fractional Head of Ethics and Integrity sets the standards, runs the whistleblowing channels and leads an independent response when a concern is raised.

  8. Not sure?

    Not sure which role you need?

    Tell us where you are regulated and why the role is needed. We will recommend the appointment your risk profile requires, not a default one.

A senior compliance officer reviewing a policy document at an oak table in a bright meeting room
Senior-led
The named individual on your appointment is the person doing the work, with the qualifications and tenure to hold it. Senior-led throughout, never delegated to junior staff.
  1. 01

    Named on the licence

    The person the regulator assesses as fit and proper is the person who does the work, day to day.

  2. 02

    Senior-led, never delegated

    No junior bench behind a senior name. The appointee holds the role and answers for it.

  3. 03

    Tenure you can check

    Relevant tenure and experience for the role, the sector and the jurisdiction, evidenced for every appointee.

Beyond licensing

Wherever you are in the journey

Authorisation is the start, not the finish. Our fractional officers stay on to run monitoring, reporting and oversight for as long as the business needs them.

01

Before licensing

We test the business plan and proposed activities so the firm is genuinely ready to be regulated before anything is filed.

02

When an application stalls

We find what has gone wrong, fix the gaps and get the conversation with the regulator moving again.

03

After launch

Ongoing oversight, reporting, training and monitoring as the business scales.

01

Not happy with your current MLRO?

We review the arrangement in place and, where needed, step in with a managed handover and minimal regulatory disruption.

02

When the regulator comes calling

Measured, accurate responses to information requests, supervisory reviews and formal investigations.

03

The right role, not a default appointment

We start by understanding why the role is needed, screen your firm and recommend the appointment your risk profile requires.

Common questions

Fractional compliance, answered

Yes. We place experienced MLROs for DIFC firms supervised by the DFSA, where the MLRO is a Licensed Function held by an Authorised Individual. The DFSA holds final acceptance of any appointment.

Yes. In ADGM the FSRA approves the Compliance Officer as an Approved Person holding a Controlled Function. We place fractional Compliance Officers and MLROs for ADGM firms, from application through ongoing supervision.

Yes, with one difference. VARA allows the MLRO role to be outsourced, so we place fractional MLROs for virtual asset service providers. VARA requires the Compliance Officer to be a full-time employee, approved by VARA as fit and proper, so there we support the officer rather than replace them.

Yes. Federal AML rules require onshore financial institutions to appoint a Compliance Officer at management level, and the Capital Market Authority approves Compliance Officers directly. We place fractional Compliance Officers for payment providers, exchange houses, finance companies, brokers and fund managers, subject to each regulator’s requirements.

An interim officer covers a gap until a permanent hire. An outsourced arrangement often places the mandate with a firm while someone else does the work. A fractional officer is a named, senior individual who holds the role on an ongoing, part-time basis and stays for as long as the business needs them.

Yes. The individual named on the appointment is the person doing the work, with the tenure and qualifications to hold it. The work is never delegated to junior staff.

No. Appointments to roles requiring regulatory approval are subject to the relevant authority’s requirements, and the regulator holds final acceptance. We place candidates with the relevant tenure and experience, and prepare them for the fit and proper assessment.

Brief a compliance search

Tell us where you are regulated and what you need.

We screen why the role is needed, triage any regulatory action and recommend the appointment your risk profile requires.

Brief a compliance search

Fractional places qualified executives into regulated appointments. We do not provide legal advice, and final acceptance of any appointment rests with the relevant regulator; we work alongside your appointed legal and compliance advisers. Appointments to roles requiring regulatory approval are subject to the relevant authority’s requirements.