What Does an MLRO Do? Outsourcing the MLRO Role in the UAE
The role of the Money Laundering Reporting Officer in UAE firms, what regulators expect, and when outsourcing the MLRO makes sense.
Every regulated firm and DNFBP in the UAE needs someone accountable for anti-money laundering. That person, called the Compliance Officer under federal rules and the MLRO under VARA, DFSA and ADGM rules, sits at the centre of the compliance programme and is a key person in the eyes of regulators.
Core responsibilities
- Owning the AML/CFT framework and keeping policies current
- Reviewing alerts and internal reports of suspicious activity
- Filing suspicious transaction and activity reports through goAML
- Managing targeted financial sanctions screening and responses
- Training staff and reporting to senior management and the board
- Acting as the point of contact for regulators and the Financial Intelligence Unit
Why firms outsource
Experienced MLROs are scarce and expensive, especially for start-ups and smaller firms. Outsourcing gives access to senior expertise, established processes and tools, and cover during holidays or turnover, often at lower cost than a full-time hire.
What to check
Regulators keep responsibility with the firm, even when a function is outsourced. Check that your regulator accepts an outsourced arrangement for your licence type, whether residency or substance requirements apply, and that the outsourced MLRO has the access, authority and time to do the job properly.
Key takeaways
- The MLRO owns the AML/CFT framework and suspicious activity reporting.
- Outsourcing provides senior expertise without a full-time hire.
- Check your regulator's expectations before outsourcing.
Related licence guides
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This article is general information, not legal advice. Regulatory requirements change; confirm current rules with the relevant regulator.