Outsourced Roles

MLRO & Outsourced Compliance Officer

Qualified, regulator-approved MLRO and Compliance Officer services for UAE regulated entities — embedded into your governance structure, accountable to your board.

MLROOCOCBUAEDFSAADGMSTR/SAR
The Problem

When You Need Compliance Capacity Without the Overhead

UAE regulators — CBUAE, DFSA, ADGM, and SCA — require regulated firms to appoint a qualified Money Laundering Reporting Officer (MLRO) and, in many cases, a dedicated Compliance Officer. These roles carry significant personal liability and require individuals with demonstrated regulatory knowledge and experience.

For small and medium regulated entities, hiring experienced compliance professionals full-time is costly and often impractical. For newly licensed firms, finding individuals who are both qualified and acceptable to the regulator adds further complexity.

Marensa Advisory provides qualified, experienced professionals who step into these roles — carrying the regulatory responsibility, executing the compliance programme, and engaging with the regulator directly on your behalf.

Discuss Your Requirements
What's Included
  • Outsourced MLRO: STR/SAR filing, AML oversight, regulatory liaison
  • Outsourced Compliance Officer: day-to-day programme management
  • Regulatory appointment submissions and fit-and-proper filings
  • AML/CFT programme ownership and maintenance
  • Board-level compliance reporting (quarterly and annual)
  • Internal and external audit liaison
  • Staff AML/CFT training delivery
  • Regulatory correspondence management
  • SAR/STR analysis and filing to UAEFIU
  • Compliance calendar management and deadline tracking
Role Breakdown

MLRO vs Compliance Officer: What Each Role Does

Money Laundering Reporting Officer (MLRO)
The MLRO is the designated AML/CFT accountability point within the firm. Responsibilities include: receiving and assessing internal suspicious activity reports, determining whether to file STRs/SARs with the UAEFIU, maintaining the firm's AML risk assessment, overseeing the AML/CFT programme, and reporting to the board on AML performance. Regulators hold the MLRO personally accountable for AML failures.
Outsourced Compliance Officer (OCO)
The Compliance Officer owns the broader regulatory compliance programme: policy frameworks, controls testing, regulatory change management, board reporting, staff training, and regulator engagement. In the UAE, CBUAE and DFSA allow compliance functions to be outsourced under specific conditions, including maintaining clear accountability lines and ensuring the outsourced officer has no conflicts of interest.
Combined MLRO + CO Function
For smaller regulated entities, it is often practical and cost-efficient to combine the MLRO and Compliance Officer roles under a single outsourced arrangement. Marensa structures these arrangements to satisfy regulator requirements on role separation while keeping costs manageable for the client firm.
Deputy MLRO
We also provide Deputy MLRO services — acting as the backup MLRO during absence periods and providing surge capacity during high-volume SAR periods. This is particularly valued by firms with a part-time compliance resource who needs qualified cover.
Who This Is For

Is This Right for You?

  • Newly licensed entities without an in-house compliance resource
  • Firms whose MLRO or Compliance Officer has departed
  • Regulated businesses requiring interim compliance cover during recruitment
  • Small and medium financial institutions needing qualified appointees
  • Offshore and IFC structures requiring local director/MLRO presence
  • RAKEZ, DIFC, ADGM, and CBUAE-licensed entities
  • Fintechs and payment service providers post-licence
Regulatory Coverage

Regulators We Work Under

  • CBUAE (Central Bank of the UAE)
  • DFSA (Dubai Financial Services Authority — DIFC)
  • ADGM (Financial Services Regulatory Authority)
  • SCA (Securities and Commodities Authority)
  • VARA (Virtual Assets Regulatory Authority)
  • Mauritius FSC
  • FINTRAC (Canada) — for cross-border MSB compliance
Our Process

How We Assume These Roles

01
Scope & Suitability Assessment
We review your regulatory licence, existing compliance framework, and governance structure to confirm that outsourcing is permitted under your applicable rules and to define the scope of the role we will assume.
02
Regulatory Appointment
We complete the regulatory appointment process — including fit-and-proper submissions and individual registration where required by CBUAE, DFSA, or ADGM. We manage all communications with the regulator during this stage.
03
Business Familiarisation
Before formally assuming the role, we conduct a structured onboarding: reviewing your AML/CFT policies, risk assessment, transaction monitoring, customer files, and existing compliance reporting. We identify gaps and remediation priorities immediately.
04
Programme Execution
We execute all obligations of the role on an ongoing basis — STR/SAR analysis and filing, board reporting, compliance calendar, regulatory correspondence, staff training, and annual programme review.
05
Transition or Handover
When you are ready to bring the function in-house or transition to a new arrangement, we manage a structured handover — ensuring your records are complete, your successor is briefed, and the regulator is notified correctly.
Get Started

Need a Qualified MLRO or Compliance Officer?

Tell us your regulator, your licence type, and your current situation. We'll advise on structure and timeline.

Related Services

You May Also Need

Ask Maya