The regulatory requirement

Firms in the Abu Dhabi Global Market ("ADGM") who are regulated by, or are seeking to be regulated by the Financial Services Regulatory Authority ("FSRA"), are required to register a Compliance Officer and Money Laundering Reporting Officer ("MLRO") with the FSRA. All Compliance Officers and MLROs must be senior managers and, unless an exemption is obtained, must be ordinarily resident in the UAE.

The role of the Compliance Officer and MLRO can be combined and held by one individual, but that individual must be appropriately qualified and/or have sufficient experience and gravitas, although currently there are no mandatory qualifications.

It is important to have someone with explicit knowledge of the FSRA rules & regulations as the ADGM's framework evolves.

Depending on the scale and complexity of the organisation, the FSRA will allow you to outsource the roles of Compliance Officer/MLRO and this can either be internally within the group or to an external provider like CCL. If you are unable to outsource these functions you will be required to have your own internal Compliance Officer and MLRO. If this is the case your internal resource may benefit from expert support from a local team with in-depth knowledge of FSRA regulations, either on an ad hoc basis or on a regular basis, for instance on the job training programmes or executing the Firm’s Compliance Monitoring Programme.

Some firms will also require a Data Protection Officer (“DPO”). The firm can either appoint someone within the organisation, rely on a group DPO or outsource the role. For further details of the requirements under the ADGM Data Protection Regulations ("DPR"), click here.

Your Compliance Officer/MLRO Outsourcing and Support options

There is no one size fits all when it comes to compliance arrangements. We have summarised the key considerations for senior management when deciding whether compliance outsourcing, an in-house compliance officer or a support contract is the right option for your Firm. Click here for details.

Whatever your requirements CCL is here to assist you to get it right first time. As first-class professionals with strong relationships with the regulators, you know you will be getting the best advice. 

Find out more about your options:

Contact our ADGM-based outsourcing team for guidance on the most suitable option for your business.

We have a dedicated team of experienced compliance consultants who can provide expert assurance and peace of mind. Get in touch to see how we can help your Firm.