Sanctuary’s Regulatory & Compliance unit houses deep knowledge and expertise, drawing on decades of experience, both from financial services regulators and regulated firms, throughout the US, the UK and of course in the Middle East region.
The team possess experience of all key regional financial services centres - DIFC, ADGM, QFC as well as the mainland regulators such as the UAE’s SCA and the Kingdom of Saudi Arabia’s CMA.
We work with both existing firms requiring support for specific projects (such as license expansions, compliance reviews, risk assessments, special projects) as well as new entrants looking to establish start-up operations.
Our team operates across the regulatory cycle, delivering advice, market intelligence, project management and key outsourced compliance and MLRO roles, from initial licensing and authorisation through to ongoing support for new and existing operations. We also work alongside our in-house Corporate Services team, to deliver establishment and commercial licensing seamlessly.
Our aim is to understand in detail your business model, and to ensure that you succeed in a compliant, robust and sustainable way, whilst delivering best-in-class compliance with regional regulators’ requirements and in doing so deliver the best outcomes with respect to your own clients’ needs and expectations.
We can cover all business sectors and have a particular strength in the areas of investment business, banking, financing, private equity, private and investment banking, asset and fund management, whilst being adaptive to other specialist and emerging sectors.
Preparing license applications for new applicants for authorisation and existing licensed firms looking to expand or vary their current operations and licences.
Preparing Regulatory Business Plans and associated supporting information, from the creation of compliance and AML/CFT procedures through to their practical implementation.
Assisting you in your corporate governance arrangements in a manner that is proportionate and appropriate to the nature, scale and complexity of your business, at its outset and as it evolves and grows.
Provision of outsourced Compliance Officer and/or MLRO roles (as well as NED roles, if desired, for more broad-based governance support), including the training and development of your own staff.
Undertaking compliance reviews and risk-based compliance monitoring to deliver assurance that your business remains compliant at both the licensing stage and on an ongoing basis thereafter.
Provision of Compliance and AML/CFT training, as well as supporting you in other disciplines such as International Sanctions and Anti Bribery & Corruption.
We will also work alongside your Finance Officer, including where you may choose to outsource this role too, as well as any existing risk management and internal audit staff you may deploy, in order to ensure a holistic overview of your firm is ensured that aligns with how regulators will exercise their oversight of your firm.
Ensuring all Approved or Authorised Individuals are in place initially as well as dealing with any subsequent changes and required regulatory approvals as your mix of staff evolves over time, whilst meeting expectations of regulators with regards to fitness and propriety, competence and capability.
Undertaking annual AML/CFT Reviews for submission to regulators where you also request this service.
The simple answer is that it depends on the regulator, its available resources, its balance between risk-based and administrative requirements, but most crucially – the completeness and thoroughness of an application for authorisation, whilst also taking into account the nature, scale and complexity of a firm’s business, structure and operations.
This is where Sanctuary will add significant value – our role is to help clients to submit high-quality applications that satisfy and anticipate likely questions, articulating your businesses in a manner that is consistent with how each individual regulator defines their requirements, and in doing so ensure that firms “get it right first time” and in the shortest possible time.
This is really a question of the risk profile of a firm - both in terms of its operations (to make sure it meets its capital requirements at all times) and any assets it may hold and control on behalf of its clients.
Broadly speaking, the higher the risk-profile and exposure (such as counterparty risk, or market risk, and including risks to customers in relation to their relevant experience, understanding and net worth), the higher the firm’s capital requirements will generally be.
Sanctuary can help you navigate the impact of conducting various activities and how this translates into regulatory capital and reporting requirements. We will guide you in optimising the capital required by defining your core-activities and balancing initial start-up plans and the capital required with longer-term plans to reflect how your business develops, grows and becomes more established.
