FractionalFRACTIONAL|ABU DHABI
Role guide · ADGM and the UAE

Fractional Compliance Officer for ADGM and UAE-regulated firms

Your Compliance Officer makes sure the firm meets its regulatory obligations day to day: the right policies, the right checks, the right records and the right reports, on time. Here is how the role works and how a fractional appointment fits.

MonitorCompliance programme
ApprovedIndividual role
OngoingFractional cover
A Compliance Officer annotating a policy binder at a light oak table in a sunlit office
At a glance

The Compliance Officer in brief

The approved individual who makes sure the firm meets its regulatory obligations day to day, and tells senior management when it does not.

Also searched as: Outsourced compliance officer, interim compliance officer
Regulatory status
A regulator-approved role: a Licensed Function (DFSA), a Controlled Function (FSRA), VARA-approved (and full-time under VARA’s rules) and a CMA-approved job. Onshore AML rules require one at management level.
Reports to
The board and senior management, with direct access to both.
Works closely with
The MLRO, finance, operations and the client-facing teams.
Where it sits
Second line: independent monitoring and advice to the first-line business.[1]
Typical commitment
Agreed days each month, sized to the firm’s activities, with more around licensing, returns and inspections.

What the rules say

  • In DIFC, the Compliance Officer is a Licensed Function approved by the DFSA, and must be a director, partner or senior manager of the firm.[2]
  • In ADGM, it is a Controlled Function held by an FSRA Approved Person. In both free zones every authorised firm must have one at all times, resident in the UAE unless the regulator grants a waiver.[3],[2]
  • VARA requires a Compliance Officer with at least five years of compliance experience, approved by VARA as fit and proper, reporting directly to the board. VARA also requires the Compliance Officer to be a full-time employee.[4]
  • Onshore, the federal AML regulations require a Compliance Officer at management level, and the CMA lists Compliance Officer as a job that needs its approval.[5],[6]
What they do

The compliance cycle

Good compliance functions share a simple loop, described by the Basel Committee for banks and by ISO 37301 for any organisation: know your obligations, turn them into policy and controls, check they work, report honestly and improve.[7],[8]

What they own

  • Compliance monitoring programme
  • Policies and procedures
  • Regulatory returns and notifications
  • Record-keeping and client-level checks
  • Staff training
  • Compliance reporting to the board
01

Map obligations

Keep a live register of the rules that apply to the firm’s licence and activities, and track changes as the regulator updates them.

02

Set policy

Write and maintain clear policies and procedures, and advise the business on new products, clients and marketing.

03

Monitor

Run a risk-based compliance monitoring programme that tests whether controls work in practice, not only on paper.

04

Report

Prepare regulatory returns and notifications, and report findings and breaches to senior management and, where required, the regulator.

05

Train

Make sure staff understand the rules that apply to their work, and keep the records that show it.

Why it matters

Why a UAE firm needs a Compliance Officer

It is a condition of most financial services licences. It is also the role that spots problems before the regulator does.

  1. 01

    It is a condition of the licence

    The DFSA and the FSRA require an approved Compliance Officer at all times, and VARA and the CMA require one too. Most applications cannot proceed without a named individual.[2],[3],[4],[6]

  2. 02

    Compliance needs independence

    The rules require the Compliance Officer to have adequate resources, independence and unrestricted access to records, senior management and the board.[9],[10]

  3. 03

    Onshore AML rules expect it too

    Every financial institution, including payment firms, exchange houses and brokers, must have a Compliance Officer at management level who monitors AML compliance, trains staff and reports to senior management.[5]

  4. 04

    It catches problems early

    A monitoring programme that tests controls finds breaches while they are small, and keeps the firm in control of how they are fixed and reported.

How it works

How a fractional Compliance Officer works with us

One brief, one accountable appointment. The person you meet is the person named on the appointment and doing the work.

01

Brief

Tell us where you are regulated, what stage you are at and why the role is needed. We screen the firm and any open regulatory matters before recommending an appointment.

02

Shortlist

We put forward senior candidates with relevant tenure in your role, sector and jurisdiction. You meet the person who will do the work, not a sales lead.

03

Approval

Where the role needs regulatory approval, we help prepare the application and the candidate for the fit and proper assessment. The regulator holds final acceptance.

04

Ongoing

Your appointee works agreed days each month, reports to your board and steps up around licensing, inspections and remediation.

The first 90 days

Days 1 to 30

Get the full picture

  • Review the licence conditions, policies and compliance manual
  • Build or check the regulatory obligations register
  • Check the calendar of returns and notifications

Days 31 to 60

Close the gaps

  • Agree a risk-based monitoring plan with senior management
  • Update policies that no longer match how the firm works
  • Fix record-keeping and breach logging

Days 61 to 90

Run the programme

  • Complete the first monitoring reviews and report the findings
  • Deliver compliance training to staff
  • Present the first compliance report to the board
Brief a search for this roleCompare all seven roles
Choosing the model

Fractional, full-time or outsourced?

All three can work. What matters to the regulator is that the person named on the appointment has the seniority, independence and time to hold it.

Fractional
Full-time hire
Outsourced provider
Who does the work
FractionalThe named senior individual you appointed
Full-time hireYour own employee
Outsourced providerA provider’s team, under a named lead
Time commitment
FractionalAgreed days each month, flexing with need
Full-time hireFull time, whatever the workload
Outsourced providerSet by the service contract
Cost basis
FractionalA share of a senior salary, for the time you use
Full-time hireFull salary, benefits, visa and hiring costs
Outsourced providerA service fee, often plus ad hoc charges
Getting started
FractionalNo full recruitment cycle
Full-time hireA full search and notice period
Outsourced providerQuick to contract
Continuity
FractionalStays as long as you need; handover planned
Full-time hireDepends on retention
Outsourced providerStaff may rotate across clients
Best when
FractionalYou need an approved, senior officer but not a full-time workload.
Full-time hireThe firm’s size and activities keep an officer busy every day.
Outsourced providerYou want monitoring support alongside an officer you already have.
When to engage

Signs it is time

  • A licence application needs a named Compliance Officer
  • A newly authorised firm is moving into steady-state operations
  • Compliance currently sits with the finance or operations lead
  • Your current officer is leaving and a handover is needed
Who we place

What good looks like

Relevant tenure and experience running compliance in regulated firms.

  • Experience as an approved Compliance Officer, or senior compliance experience in a regulated firm
  • Knowledge of your regulator’s rulebook and returns
  • Experience designing and running a monitoring programme
  • Clear, practical advice the business can act on
Brief a search for this role
Related roles

Often appointed alongside

Most regulated firms need more than one of these roles. Each has its own guide.

  1. Money Laundering Reporting Officer (MLRO)The senior individual who owns your anti-money laundering framework, decides what is reported to the authorities and answers for it to the regulator.
  2. Head of ComplianceThe senior leader accountable for the whole compliance framework, who oversees the Compliance Officer and MLRO and represents the firm to the regulator.
  3. Chief Risk Officer (Head of Risk)The senior leader who identifies and measures the risks the firm runs, agrees with the board how much risk it will take, and reports honestly against that limit.
All seven Risk and Compliance roles
Common questions

Compliance Officer, answered

It depends on the regulator. In DIFC, yes: the Compliance Officer must be a director, partner or senior manager, and the DFSA’s definition of employee includes people engaged under a contract for services. In ADGM, the FSRA approves each appointment and looks at whether the person has the time and independence for it. Under VARA, no: the Compliance Officer must be a full-time employee, so a fractional appointment there supports the officer rather than replacing them. Onshore, the CMA allows the head of compliance to be outsourced with its consent.

Often, yes. In DIFC one person can hold both functions if they can do both effectively and conflicts are managed, but not alongside the Senior Executive Officer or Finance Officer roles. VARA also allows the roles to be combined where duties do not conflict.

In DIFC and ADGM, yes, unless the regulator grants a waiver. VARA requires the Compliance Officer to be UAE resident or a UAE passport holder.

The Compliance Officer covers the firm’s regulatory obligations as a whole: conduct, client rules, returns and notifications. The MLRO focuses on money laundering, terrorist financing and sanctions. Smaller firms often combine them; larger or higher-risk firms keep them apart.

Brief a compliance search

Need a Compliance Officer? Tell us where you are regulated.

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

Brief a search for this role

Sources

  1. [1]The Institute of Internal Auditors, Three Lines Model: Assurance and Advice in Support of Effective Governance (2026).
  2. [2]Dubai Financial Services Authority, DFSA Rulebook, General Module (GEN), GEN 7.4 to 7.5, Licensed Functions and mandatory appointments.
  3. [3]ADGM Financial Services Regulatory Authority, General Rulebook (GEN), GEN 5.3 and 5.5, Controlled Functions and Approved Persons.
  4. [4]Virtual Assets Regulatory Authority, Compliance and Risk Management Rulebook, Part I (Compliance Officer, risk management) and Part III (MLRO).
  5. [5]United Arab Emirates, Cabinet Resolution No. 134 of 2025, Executive Regulations of Federal Decree-Law No. 10 of 2025, Articles 21 and 22, the Compliance Officer.
  6. [6]Capital Market Authority, Rulebook, Section 2: Licensing of Financial Activities and Jobs Approval, Chapter 6, approved jobs.
  7. [7]Basel Committee on Banking Supervision, Compliance and the compliance function in banks (2005).
  8. [8]International Organization for Standardization, ISO 37301:2021 Compliance management systems.
  9. [9]Dubai Financial Services Authority, DFSA Rulebook, General Module (GEN), GEN 5.3.7 to 5.3.12, compliance arrangements.
  10. [10]ADGM Financial Services Regulatory Authority, General Rulebook (GEN), GEN 3.3, risk management and compliance arrangements.

Plain-English summaries, reviewed September 2026. Rulebooks change, so always check the current text. 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.