Outsourced MLRO & Compliance Officer

For firms in set-up or transition, we provide interim and outsourced MLRO and Compliance Officer services. Our appointments are led by a regulator-approved MLRO and Compliance Officer, registered with the DFSA and the Ministry of Economy and Tourism, who brings immediate credibility and operational capability to your function.

Beyond holding the function, we focus on knowledge transfer, building your internal capability and creating a compliance culture that lasts long after our appointment ends.

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Core capabilities

What the engagement covers

Interim Authorised Individuals

Regulator-approvable MLRO, Deputy MLRO and Compliance Officer cover at short notice, with the seniority and track record supervisors expect.

Outsourced Compliance Function

A full compliance function delivered as a service: risk assessment, monitoring plan, policy suite, testing and board reporting on a fixed cadence.

Regulatory Liaison & Reporting

Day-to-day regulatory liaison, from notifications and information requests to STR/SAR filing through goAML and periodic returns.

Staff Mentoring & Handover

Structured coaching of your internal successor so the function transfers cleanly, with documented procedures and an evidenced audit trail.

Business-Wide Risk Assessment

Enterprise-wide ML, TF, PF and sanctions risk assessment methodology, scoring model and annual refresh, approved and minuted at board level.

Compliance Monitoring Programme

Risk-based testing plan with sampling methodology, findings register and remediation tracking that stands up to inspection.

Policies, Procedures & Controls

AML/CFT and CPF manual, sanctions policy, CDD and EDD procedures and escalation matrices calibrated to your licence and customer base.

Training & Compliance Culture

Role-specific AML and conduct training for the board, front line and support functions, with attendance and competence records maintained.

When firms appoint an outsourced MLRO

The function cannot sit vacant. These are the moments when external cover is the fastest route to a compliant, credible position.

Pre-licence and set-up

A named, approvable candidate is required before the regulator will grant authorisation.

Sudden departure

The resignation or removal of an authorised individual leaves a gap that must be notified and filled.

Post-inspection remediation

Supervisory findings call for senior capability and independent challenge, at pace.

Growth and scale-up

Volume or product expansion outpaces the capacity of an existing part-time appointee.

Group restructuring

New entities, redomiciliation or a change of control that resets the compliance perimeter.

DNFBP registration

Real estate brokers, dealers in precious metals and stones, auditors and accountants, and corporate service providers meeting Ministry of Economy and Tourism and goAML obligations.

How the appointment works

01

Scope & candidate fit

We size the time commitment against your risk profile and confirm a candidate the regulator can approve.

02

Approval & mobilisation

We prepare the authorised individual application and provide shadow cover so the function is never uncovered.

03

Run the function

Risk assessment, monitoring, reporting and regulatory liaison delivered on an agreed cadence, with board visibility.

04

Transfer & exit

We mentor your successor, document everything and hand over, with regulator notification where required.

Who this is for

Newly licensed and pre-licence firms, payment institutions, exchange houses, brokers and asset managers, virtual asset service providers, insurance intermediaries, and DNFBPs with Ministry of Economy and Tourism and goAML obligations.

A regulator-approved individual in post without a permanent hire
Immediate senior capability and independent challenge from week one
Internal capability built through mentoring, not dependency
A documented, inspection-ready compliance function on exit
FAQ

Common questions

What is an outsourced MLRO?

An outsourced MLRO is an external, regulator-approved individual appointed to hold the Money Laundering Reporting Officer function on behalf of a firm. They carry the same accountability as an in-house appointee while the firm builds its internal capability.

Can a UAE regulated firm outsource the MLRO function?

In many cases, yes. Most UAE regulators allow the MLRO or Compliance Officer function to be outsourced or held by an external individual, subject to conditions such as approval of the individual, adequate time commitment, UAE residence where required, and clear board oversight. The rules differ by regulator and licence category, so we confirm the position for your firm first.

How quickly can an interim MLRO be appointed?

We can usually mobilise within days. Formal approval then follows the regulator’s own timeline, and we provide shadow support throughout so the function is never uncovered.

What happens when the engagement ends?

Every engagement includes a structured handover: documented procedures, a trained internal successor, an evidenced audit trail and a transition plan agreed with the regulator where notification is required.

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Cover the function. Build the capability.

Tell us where the gap is and we’ll put a senior, approvable candidate in front of you.

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