Regulatory Compliance

Compliance leadership,
without the hire.

A regulator-approved Compliance Officer for your firm — covering both DFSA Compliance Officer (DIFC) and FSRA Compliance Officer (ADGM) roles. End-to-end compliance leadership without the cost of a full-time hire.

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The CO role

The Compliance Officer is the senior person responsible for your firm's overall compliance programme — not just AML, but the full spectrum of rulebook compliance, regulator reporting, breach management and committee oversight.

For DFSA and FSRA regulated firms, the CO must be named with the regulator and is typically an Authorised Individual. We provide outsourced COs for firms that don't have the volume to justify a full-time hire.

What we cover

  • Named Compliance Officer — registered with your regulator
  • Day-to-day compliance oversight — rulebook compliance across all relevant chapters
  • Regulator liaison — primary contact for regulatory queries and ongoing supervision
  • Regulatory reporting — periodic returns, breach notifications, capital adequacy reports
  • Breach management — investigation, escalation, regulator notification where required, and remediation
  • Committee participation — attendance at compliance, risk and board committees
  • Policy framework — owning and updating the firm's compliance policies and procedures
  • Annual compliance plan — risk-based plan agreed with senior management
  • Annual compliance report — to the board on the state of the compliance programme
Compliance Officer framework

DFSA & FSRA
Compliance Officer duties.

The Compliance Officer (CO) is one of the four mandatory Authorised Individual functions under the DFSA GEN Rulebook (for DIFC firms) and the FSRA GEN Rulebook (for ADGM firms). The CO is responsible for ensuring the firm complies with its regulatory rulebook on an ongoing basis — separate from, but often combined with, the MLRO function.

Day-to-day responsibilities

  • Maintain the firm's compliance programme and rulebook mapping
  • Monitor day-to-day compliance with the regulator's rules
  • Investigate and escalate breaches, file breach notifications to the regulator
  • Act as the firm's main point of contact with the regulator
  • Submit periodic regulatory returns and notifications
  • Provide compliance input on new products, activities and counterparties
  • Report to the board and senior management on compliance matters

DFSA vs FSRA — same role, different rulebook

The DFSA and FSRA frameworks are similar but not identical. DFSA Conduct of Business (COB), GEN, AUT and PRU modules apply to DIFC firms. FSRA's equivalent rulebook modules — COBS, GEN, MIR — apply to ADGM. A Compliance Officer covering both jurisdictions needs deep familiarity with both rulebooks. Our team includes individuals approved by both DFSA and FSRA, so we can serve firms with operations in either or both centres.

How we operate

What we deliver
each month.

Monthly compliance monitoring

Compliance testing against your rulebook — sample testing of client onboarding, transactions, marketing, training records, conflicts management.

Regulatory returns and notifications

All periodic regulatory submissions — DFSA prudential returns, AML quarterly reports, FSRA capital returns, conduct returns, ad hoc notifications.

Governance support

Attendance at your governance meetings (audit committee, risk committee, board). Compliance MI pack for each meeting. Action tracking.

Regulatory liaison

First point of contact for the DFSA or FSRA. We attend regulator meetings, respond to information requests, manage thematic reviews and supervisory inspections.

FAQ

Frequently asked.

What is a DFSA Compliance Officer?+
The DFSA Compliance Officer is a mandatory Authorised Individual function for all DIFC-licensed firms regulated by the Dubai Financial Services Authority. The CO is responsible for ensuring the firm complies with the DFSA rulebook on an ongoing basis.
What is an FSRA Compliance Officer?+
The FSRA Compliance Officer is the equivalent mandatory function for firms regulated by the Financial Services Regulatory Authority in ADGM. The role mirrors the DFSA CO function but operates under the FSRA rulebook.
Can the same person be CO and MLRO?+
Yes — DFSA and FSRA permit the CO and MLRO functions to be combined and held by one individual, provided that individual has sufficient knowledge, experience, seniority and capacity. This is common for smaller firms.
Can we outsource the CO role?+
Yes — both DFSA and FSRA permit outsourcing of the CO function, subject to outsourcing controls. We provide regulator-approved Authorised Individuals to act as your outsourced CO across DIFC and ADGM.
How is your fee structured?+
Outsourced CO fees are typically a fixed monthly retainer based on the size of the firm, number of regulated activities, transaction volume, and regulator. Includes all standard monthly monitoring, governance attendance and regulatory liaison. Bespoke project work (thematic reviews, inspections, regulator-led investigations) is billed separately.
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