The Dubai Financial Services Authority (DFSA) has released Consultation Paper 165 proposing changes to its Licensed Functions and Authorised Individuals regime, including removing DFSA prior approval for the appointment of Compliance Officers, Finance Officers and Senior Managers at Authorised Firms and shifting responsibility for fitness and propriety assessments more squarely to firms. Under the proposals, these roles would cease to be Licensed Functions and instead become “Designated Functions” performed by “Designated Individuals”, while the Senior Executive Officer and Money Laundering Reporting Officer would remain DFSA-authorised Licensed Functions. Authorised Firms would apply the existing fit and proper criteria (integrity, competence and capability, and financial soundness) to Designated Individuals, retain assessment records for DFSA review, notify the DFSA within seven calendar days of appointments and cessations (including reasons), and provide an annual attestation of ongoing suitability alongside the annual return. The DFSA also proposes clarifications to the definitions of Compliance Officer, Finance Officer and Senior Manager, consults on whether Finance Officers should remain mandatory for Lower Prudential Risk Firms, extends the current Principles for Authorised Individuals to Designated Individuals and applies Principles 1–4 to most other relevant employees as “Conduct Principles”, and would publish Designated Individuals on the DFSA public register. The proposals would apply to Authorised Firms only, and would not affect Authorised Market Institutions, Designated Non-Financial Business or Professions, Representative Offices or Registered Auditors. Comments are due by 5 May 2025. Subject to consultation feedback, the DFSA intends to publish Rulebook changes in July 2025 and proposes an in-force date of 1 September 2025, with existing incumbents in scope automatically transitioning to Designated Individuals unless firms notify changes; the DFSA also plans to host a webinar during the consultation period.
Dubai Financial Services Authority 2025-03-06
Dubai Financial Services Authority consults on reclassifying Compliance Officers Finance Officers and Senior Managers as firm-appointed Designated Individuals
The Dubai Financial Services Authority (DFSA) issued Consultation Paper 165 proposing changes to its Licensed Functions and Authorised Individuals regime. It removes DFSA prior approval for certain roles, shifting fitness and propriety assessments to firms. Compliance Officers, Finance Officers, and Senior Managers are reclassified as "Designated Functions," while DFSA authorization remains for Senior Executive Officers and Money Laundering Reporting Officers. Authorised Firms would apply existing criteria to Designated Individuals, maintain assessment records, and notify the DFSA of appointments and cessations.