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Role guide · ADGM and the UAE

Fractional Head of Financial Crime for ADGM and UAE-regulated firms

Money laundering, sanctions evasion, fraud and bribery rarely arrive one at a time. A Head of Financial Crime brings the controls for all of them together, and tests that they work in practice.

AMLAnd sanctions
FraudAnd bribery
OngoingFractional cover
A Head of Financial Crime walking and talking with a colleague along a bright office corridor
At a glance

The Head of Financial Crime in brief

The senior specialist who owns the firm’s defences against money laundering, sanctions breaches, fraud and bribery, and proves they work.

Also searched as: Financial crime compliance lead, Head of AML
Regulatory status
Not usually an approved role, unless the holder is also the MLRO or, onshore, the Compliance Officer.
Reports to
The chief executive or Head of Compliance, with a line to the board.
Works closely with
The MLRO, Deputy MLRO, Chief Risk Officer, operations and technology.
Where it sits
Second line: financial crime policy, oversight and testing.[1]
Typical commitment
Agreed days each month, weighted to control testing, remediation and new-product reviews.

What the rules say

  • No UAE regulator licenses Head of Financial Crime as a title. It is usually not an approved role, unless the holder is also the MLRO or, onshore, the Compliance Officer.[2],[3]
  • UAE law requires regulated firms to assess their money laundering, terrorist financing and proliferation financing risks, carry out customer due diligence and apply the Executive Office’s sanctions instructions without delay.[4],[5]
  • The FATF Recommendations, which UAE law implements, cover the same ground: a risk-based approach, due diligence, internal controls and suspicious transaction reporting.[6]
What they do

Prevent, detect, respond

A financial crime framework works in three layers, drawn from the FATF Recommendations and industry guidance such as the Wolfsberg Group’s: prevent bad actors getting in, detect what gets through, and respond quickly and properly when something is found.[6],[7]

What they own

  • Financial crime risk assessment
  • AML/CFT and sanctions control design and testing
  • KYC, CDD and EDD standards
  • Fraud and bribery controls
  • Financial crime management information
01

Assess

Run the financial crime risk assessment across money laundering, terrorist financing, sanctions, fraud, bribery and corruption.

02

Prevent

Set the know your customer, due diligence and enhanced due diligence standards, and the anti-bribery and fraud controls.

03

Detect

Oversee sanctions screening and transaction monitoring, and make sure the rules fit the actual client base.

04

Respond

Lead investigations, sanctions matches and escalations, working with the MLRO on what is reported.

05

Test

Test controls end to end, report financial crime management information to the board and drive remediation.

Why it matters

Why a UAE firm needs a Head of Financial Crime

Financial crime risk sits at the centre of every UAE licence. The controls need an owner with the experience to test them.

  1. 01

    The law is broad

    UAE law covers money laundering, terrorist financing and proliferation financing, and expects firms to assess and manage all three, not only the first.[4]

  2. 02

    Sanctions breaches are criminal

    Sanctions instructions apply without delay, and failing to apply them carries imprisonment or a fine.[5],[4]

  3. 03

    Fraud and bribery sit alongside AML

    ISO 37001 sets out what an anti-bribery programme should include. Many firms bring fraud and bribery controls under the same owner as AML.[8]

  4. 04

    Controls must work in practice

    Industry guidance from the Wolfsberg Group focuses on effectiveness: showing that controls actually detect and stop financial crime, not just that policies exist.[7]

How it works

How a fractional Head of Financial Crime 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

Assess

  • Review the financial crime risk assessment and policies
  • Walk through screening and monitoring from alert to outcome
  • Check open findings from the regulator or auditors

Days 31 to 60

Strengthen

  • Close the highest-risk gaps first
  • Tune screening and monitoring rules
  • Refresh due diligence standards for higher-risk clients

Days 61 to 90

Prove it works

  • Test a sample of controls end to end
  • Set financial crime management information for the board
  • Agree the ongoing testing plan
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 financial crime expertise to design, test and fix controls.
Full-time hireThe firm runs large client volumes or complex cross-border flows every day.
Outsourced providerYou need a defined review, such as a one-off look-back or model validation.
When to engage

Signs it is time

  • The client base is growing faster than the controls
  • A regulator or auditor has raised a sanctions or AML finding
  • The MLRO needs senior financial crime support
  • You are expanding into higher-risk markets or products
Who we place

What good looks like

Relevant tenure and experience in financial crime compliance.

  • Experience leading financial crime or AML functions
  • Depth in sanctions, fraud and anti-bribery, not only AML
  • Experience testing controls and running remediation
  • Familiarity with screening and monitoring systems
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. Deputy MLROThe MLRO’s second in command: shares the anti-money laundering workload and takes over the role, with its responsibilities, whenever the MLRO is unavailable.
  3. Head of Ethics and IntegrityThe senior leader who sets the firm’s standards of conduct, runs its whistleblowing channels and leads an independent response when a concern is raised.
All seven Risk and Compliance roles
Common questions

Head of Financial Crime, answered

The MLRO is the approved individual who decides what is reported to the authorities. A Head of Financial Crime usually has a wider brief, covering sanctions, fraud and bribery as well as money laundering, and focuses on designing and testing controls. In smaller firms the MLRO often does both.

Not usually. It does if the same person also holds the MLRO function, or is the onshore Compliance Officer.

When client volumes, cross-border flows or product complexity mean the MLRO cannot also design and test every control, or when a regulator or auditor has found gaps that need senior remediation.

Yes. We place financial crime leaders who have run sanctions screening and escalation, including applying the UAE list and UN sanctions under Cabinet Resolution No. 74 of 2020.

Brief a compliance search

Need a Head of Financial Crime? 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]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.
  4. [4]United Arab Emirates, Federal Decree-Law No. 10 of 2025 on Anti-Money Laundering, Combating the Financing of Terrorism and Proliferation Financing, Articles 18, 19, 29 and 37.
  5. [5]Executive Office for Control and Non-Proliferation, Cabinet Resolution No. 74 of 2020 on the UAE list of terrorists and targeted financial sanctions.
  6. [6]Financial Action Task Force, The FATF Recommendations, Recommendations 1, 6, 10, 18 and 20.
  7. [7]The Wolfsberg Group, Guidance on effective financial crime programmes.
  8. [8]International Organization for Standardization, ISO 37001:2025 Anti-bribery management systems.

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.