The Dubai Financial Services Authority published a thematic review on continuing professional development (CPD) for Money Laundering Reporting Officers (MLROs) at Authorised Firms operating in or from the Dubai International Financial Centre. The review assesses compliance with MLRO CPD obligations and how firms support MLRO learning, and sets expectations for firms and MLROs to address identified gaps in CPD quality, record-keeping and employer engagement. The review analysed 2023 annual AML return data and CPD logs and interviewed 40 MLROs representing 75 firms. While 93% of firms reported their MLRO completed at least the minimum 15 hours of CPD, the DFSA’s validity assessment concluded a 79% compliance rate for MLROs at Authorised Firms, with outsourced MLROs at 90% compliance and in-house MLROs at 83%. Pure MLROs achieved 100% compliance versus 73% for hybrid MLROs, and all cases where the 15-hour minimum was not met at Authorised Firms were within hybrid roles. Common issues included CPD logs containing invalid or insufficiently structured activities, a “bare minimum” approach that led to shortfalls once invalid hours were excluded, heavy reliance on free training and basic internal e-learning, limited tailoring of CPD to a firm’s business model, and inconsistent CPD record-keeping. The DFSA also flagged scope concerns, including limited uptake of targeted financial sanctions training by many MLROs and, conversely, over-reliance on sanctions-only training by a small number. Employer financial support was generally present, but the DFSA identified room to improve non-financial support such as Learning and Development frameworks and adequate working time for CPD. Firms and MLROs are expected to review the findings and take steps that can be evidenced in future DFSA risk assessments. The DFSA will consider initiatives to clarify CPD rule requirements, including for hybrid roles, and is considering whether further guidance or a standard template for CPD logs is needed.

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