Unlike many jurisdictions, the financial free zones of the Abu Dhabi Global Market (“ADGM”) and the Dubai International Financial Centre (“DIFC”) allow firms to employ an outsourced individual as a Compliance Officer (“CO”)/Money Laundering Reporting Officer (“MLRO”).
For many firms this is a cost-effective proposition compared to hiring an internal resource but is not always the best option for some firms.
There is no “one-size-fits-all” solution when it comes to compliance arrangements a firm should adopt. However, by considering the pros and cons, you should be able to identify what is right for your business.
Key considerations for senior management
To help senior management with the process of identifying the right option for your Firm, we have summarised the key areas for you to consider. Download our full comparison to help you decide - is it full compliance outsourcing, an in-house Compliance Officer or the middle-ground - a support contract?
|Recruitment||No recruitment fees. Immediate start. Selection of experienced consultants.||Takes time to identify the right candidate. Notice period before starting.|
|Cost||Retainer basis, costs increase as business increases. Best suited to: - Small to medium sized firms - Reasonable size client base.||Salary plus end of service, DEWS (DIFC only), medical insurance, visa costs. Best suited to: - Larger firms (number of transactions and employees) - High client volumes with retail endorsement|
|Type of Business||Non-high-risk businesses.||High-risk businesses.|
|Regulatory Connections||Greater exposure to the regulator.||Limited exposure to the regulator.|
|Knowledge, Experience and Expertise||Access to a team of compliance consultants. Wide range and depth of experience of the role and the local regulatory environments. Regular training and development. Market overview of best practice||In-depth knowledge of your business. Ongoing training and development must be provided.|
|Compliance Cover||A compliance resource will always be available. When your CO/MLRO is on leave there will be another consultant assigned to cover.||Small teams can lead to absence of adequate compliance coverage. Succession planning and temporary cover arrangements required to be in place.|
The full comparison includes Regulatory Awareness, Corporate Culture, Benchmarking against Best Practice, Independence, Accountability and Accessibility. Download it now.
Have you come to a conclusion?
You may have gone through this list and come up with a clear path. It may be that compliance/MLRO outsourcing does indeed seem like a good option or you could be clear that you do need an internal resource. It could also be that you are still not completely sure which is the best option, or you may be simply looking at how you can support your internal resource without the need to increase the size of the team. There is still a middle ground to consider: compliance support. Download the full article for further details.
What should you do now?
Contact us to discuss your compliance arrangements and how we can support any gaps you may have, whether that is full Compliance Officer and MLRO outsourcing or a support arrangement to provide local cover for your central compliance function.