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Role guide · ADGM and the UAE

Fractional Head of Compliance for ADGM and UAE-regulated firms

When a business model is complex or the client book carries more risk, one senior leader needs to own the whole compliance framework. That is the Head of Compliance.

FrameworkOwns the whole system
BoardReports directly
OngoingFractional cover
A Head of Compliance leading a discussion in a bright meeting room overlooking the Dubai skyline
At a glance

The Head of Compliance in brief

The senior leader accountable for the whole compliance framework, who oversees the Compliance Officer and MLRO and represents the firm to the regulator.

Also searched as: Chief Compliance Officer, Head of Compliance and MLRO
Regulatory status
Usually holds the Compliance Officer function, as a senior manager.
Reports to
The chief executive and the board, often through a risk or audit committee.
Works closely with
The MLRO, Compliance Officer, Chief Risk Officer and internal audit.
Where it sits
Second line, leading it.[1]
Typical commitment
Agreed days each month, weighted to board cycles, regulator meetings and escalations.

What the rules say

  • No UAE regulator uses Head of Compliance as a licensed title. In DIFC and ADGM the person leading compliance usually holds the approved Compliance Officer function, which must sit with a director, partner or senior manager.[2],[3]
  • In DIFC the Compliance Officer cannot also be the Senior Executive Officer or Finance Officer, and ADGM guidance expects the Compliance Officer and Senior Executive Officer roles to be kept separate.[2],[3]
  • CBUAE-licensed banks must run an independent, permanent compliance function. Its head is part of senior management, and the bank needs CBUAE no-objection before appointing them.[4],[5]
  • The CMA allows a firm to outsource its head of compliance with the Authority’s consent.[6]
What they do

Leading a compliance management system

ISO 37301 describes what a complete compliance framework looks like, whatever the sector: leadership and culture, a clear view of obligations and risks, resources and controls, checks that they work, and continual improvement. A Head of Compliance is accountable for all of it.[7]

What they own

  • Overall compliance framework
  • Escalation handling
  • Oversight of the MLRO and Compliance Officer
  • Regulator engagement
  • Board and committee reporting
01

Lead

Set the tone with the board, agree the compliance strategy and make sure compliance has the authority and resources it needs.

02

Plan

Keep the compliance risk assessment current and set the annual plan: what gets monitored, trained and reviewed.

03

Resource

Build the team, whether employed, fractional or outsourced, and oversee the Compliance Officer and MLRO.

04

Assure

Review whether the framework works, handle escalations and lead the firm’s response to regulatory reviews.

05

Improve

Fix root causes, not only symptoms, and report progress to the board.

Why it matters

Why a UAE firm needs a Head of Compliance

Smaller firms often combine the roles. As the risk grows, one person needs to own the whole picture.

  1. 01

    One owner for the whole framework

    Regulators expect compliance arrangements that are independent, properly resourced and have direct access to the board. In a larger or higher-risk firm that takes a senior leader, not only an officer.[8],[9]

  2. 02

    Independence needs weight

    The rules stop the Compliance Officer from also running the business. A Head of Compliance with real standing makes that independence count in the boardroom.[2]

  3. 03

    Banks need it by rule

    CBUAE-licensed banks must have an independent, permanent compliance function, led by a head of compliance the Central Bank has not objected to.[4],[5]

  4. 04

    The regulator wants one senior voice

    Supervisory meetings, remediation programmes and difficult notifications go better with one senior person who knows the whole picture.

How it works

How a fractional Head of Compliance 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

Diagnose

  • Assess the framework against the rulebook and the firm’s risk
  • Meet the board, the MLRO and the Compliance Officer
  • Review open regulatory matters and commitments

Days 31 to 60

Set direction

  • Agree the compliance strategy and plan with the board
  • Clarify roles, reporting lines and escalation routes
  • Prioritise remediation and resourcing

Days 61 to 90

Embed

  • Launch the monitoring and assurance plan
  • Take over the relationship with the regulator
  • Report progress to the board or committee
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 senior leadership and accountability, but the team underneath can run day to day.
Full-time hireA large, multi-jurisdiction business needs a full-time leader.
Outsourced providerYou want a service provider to run defined compliance tasks under your own leader.
When to engage

Signs it is time

  • Higher-risk or higher-complexity business
  • A firm facing regulatory scrutiny
  • A licence application that has lost momentum
  • A growing team that needs one accountable compliance lead
  • The board wants independent assurance that compliance is working
Who we place

What good looks like

Relevant tenure and experience leading compliance functions.

  • Experience leading a compliance function, not only working in one
  • A track record with regulators, including difficult conversations
  • The standing to challenge the board and senior management
  • Experience in your sector and jurisdiction
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. Compliance OfficerThe approved individual who makes sure the firm meets its regulatory obligations day to day, and tells senior management when it does not.
  2. 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.
  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

Head of Compliance, answered

Compliance Officer is the regulatory function; Head of Compliance is a leadership title. In a small firm they are the same person. In a larger one, the Head of Compliance leads the function, oversees the Compliance Officer and MLRO, and may hold the approved Compliance Officer function themselves.

Broadly, yes. Chief Compliance Officer is common in larger or international groups; Head of Compliance is more usual in the UAE. The job is the same: accountability for the whole compliance framework.

Yes, where the team underneath runs the day-to-day work and the regulator is satisfied the individual has the time and seniority. The CMA, for example, allows the head of compliance to be outsourced with its consent. At a CBUAE bank, the appointment needs the Central Bank’s no-objection.

If they hold the Compliance Officer function in DIFC or ADGM, yes. At a CBUAE bank the Central Bank must give its no-objection. Elsewhere it depends on the function they hold.

Brief a compliance search

Need a Head of Compliance? 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]Central Bank of the UAE, Internal Controls, Compliance and Internal Audit Regulation (Circular 161/2018), Article 3.
  5. [5]Central Bank of the UAE, Corporate Governance Regulation for Banks (Circular 83/2019), Articles 1 and 5, senior management appointments.
  6. [6]Capital Market Authority, Rulebook, Section 2: Licensing of Financial Activities and Jobs Approval, Chapter 6, approved jobs.
  7. [7]International Organization for Standardization, ISO 37301:2021 Compliance management systems.
  8. [8]Dubai Financial Services Authority, DFSA Rulebook, General Module (GEN), GEN 5.3.7 to 5.3.12, compliance arrangements.
  9. [9]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.