Interim Authorised Individuals
Regulator-approved MLRO, Deputy MLRO and Compliance Officer candidates placed at short notice, with the seniority and track record supervisors expect.
Independent MLRO & Compliance Services
For firms in setup phase or transition, we provide interim and outsourced MLRO and Compliance Officer services. We deploy senior, regulator-approved individuals who bring immediate credibility and operational capability to your function.
Beyond simply holding the authorized function, we focus on knowledge transfer, building your internal capabilities, and establishing a compliance culture that persists long after our tenure concludes.
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Core capabilities
What the engagement covers
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
We own the regulator relationship day to day notifications, information requests, 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 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 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 board, front line and support functions, with attendance and competence records maintained.
When firms appoint an independent 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 setup
A named, approvable candidate is required before the regulator will grant authorisation.
Sudden departure
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, precious metals, audit and corporate service providers meeting MOE and goAML duties.
How the appointment works
01
Scope & candidate fit
We size the time commitment against your risk profile and match a candidate the regulator will 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 regulator 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 carrying goAML and MOE 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 independent or outsourced MLRO?
An independent MLRO is an external, regulator-approved individual appointed to hold the Money Laundering Reporting Officer function on behalf of a regulated firm, carrying the same accountability as an in-house appointee while the firm builds internal capability.
Can a UAE regulated firm outsource the MLRO function?
Yes. The DFSA, FSRA, CBUAE and VARA permit outsourcing of the MLRO and Compliance Officer functions subject to approval of the individual, adequate time commitment, local presence where required, and clear board oversight.
How quickly can an interim MLRO be appointed?
We can typically mobilise a candidate within days, with formal approval following the authority’s assessment timeline. Shadow support runs from day one 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.