Regulatory Compliance

Sanctuary’s Regulatory & Compliance team has deep knowledge and expertise, drawing on decades of experience as financial services regulators and providers in the US, UK and the GCC.

This means that we are able to provide tailored advice and solutions in all regional offshore & mainland jurisdictions - DIFC, ADGM, SCA in the UAE, QFC in Qatar and the Kingdom of Saudi Arabia’s CMA.

Sanctuary can provide support to existing firms for specific projects - license expansions, compliance reviews, risk assessments and special projects as well as new entrants looking to establish operations.

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How our Regulatory Services Operate

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.

Our Regulatory Compliance Services

Licence Applications

Preparing licence applications for new applicants for authorisation and existing licensed firms looking to expand or vary their current operations and licences.

Regulatory Business Plans

Preparing Regulatory Business Plans and associated supporting information, from the creation of compliance and AML/CFT procedures through to their practical implementation.

Corporate Governance

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.

Compliance Officer

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.

Compliance Reviews

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.

Compliance and AML/CFT training

Provision of Compliance and AML/CFT training, as well as supporting you in other disciplines such as International Sanctions and Anti Bribery & Corruption.

Finance Officer Assistance

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.

Authorised Individuals

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.

AML/CFT reviews

Undertaking annual AML/CFT Reviews for submission to regulators where you also request this service.

FAQ

What are regulated businesses in the UAE?

In the UAE, regulated businesses are those that require additional approvals and licences due to their impact on public interest or the economy. These businesses are subject to strict regulatory oversight and compliance requirements.

Why does my business need regulatory approvals?

In the UAE, there are certain business activities that require additional approval and licensing. These businesses activities are subject to heightened regulatory requirements and monitoring to ensure legal compliance and integrity within the industry.

Where can regulated companies set up?

The appropriate jurisdiction for a regulated entity will depend on the nature of the business and its activities. The UAE offers a wealth of specialised jurisdictions in both the Mainland and Free Zone. These include the Abu Dhabi Global Market (ADGM), Dubai International Financial Centre (DIFC), and Dubai Multi Commodities Centre (DMCC) free zones, which are key jurisdictions for financial and professional services in the fintech and digital asset sectors.

How long does it take to become licensed?

This 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.

How much capital will I need?

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.

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