DFSA Publishes Findings of a Thematic Review of Client Classification and Suitability

In 2016, the Dubai Financial Services Authority (DFSA) carried out a thematic review to determine how Authorised Firms carried out client classification assessments and how they documented it. The review followed changes to the client classification rules that came into force in April 2015.

The review had four phases:

Phase One - A survey issued to 217 Authorised Firms. The response rate was 89%.

Phase Two - A desk-based assessment of the survey results.

Phase Three – On-site visits to 22 Authorised Firms offering a range of financial services across each of the DFSA licence categories. Interviews were conducted with key staff and client files were reviewed to assess the firm’s record keeping and implementation of client classification and suitability procedures.

Phase Four – Analysis, observations and report write up.

Since the client classification rules came into effect, Authorised Firms have been required to classify Professional Clients as ‘deemed’, ‘service based’ or ‘assessed’.

The Client classification process involves a qualitative assessment of a client’s knowledge and experience. The Authorised Firm must document the decision-making process and record the client classification.

The DFSA’s Client Classification and Suitability Thematic Review 2017 report highlights both good and bad practices. The following concerns were noted

• Employees performing client classification are not receiving sufficient training and guidance.
• There is a lack of clear documentation supporting how client classifications were assessed.
• Assessments were more tick-box than detailed and qualitative.

Concerns relating to Suitability were:

• Failure to carry out or document assessments in connection with advice or discretionary transactions.
• The use of suitability waivers in Client Agreements to limit obligations, liability or duties with regards to suitability.
• Inadequacies in internal policies and procedures relating to suitability and client classification.

The DFSA provides the following recommendations to improvement systems and controls including:

• Improve policies and procedures to ensure there is sufficient guidance on how to assess clients and record the final classification.
• Train staff on how to carry out assessments and record decision making.
• Suitability waivers should not be included in client documentation – it is not possible for a client to waive suitability obligations and responsibilities.  

The full report, which also details best practice can be read at https://www.dfsa.ae/CMSPages/GetFile.aspx?guid=1b6dfb0e-ba8f-4ff7-94ce-6615d4a61cd6

If you would like HOLT consultancy to review your client files please contact us using info@holtconsultancy.com or call +971 4 386 6360.

HOLT consultancy is recruiting for a Compliance Officer

Compliance Officer

HOLT consultancy LLC is an award winning professional compliance and risk management service provider, based in the DIFC. It was established in 2012. Its reputation within the DIFC has attracted some large clients who require expertise in licence applications and outsourced Compliance Officer and Money Laundering Reporting Officer (MLRO) services.

We are a friendly team who work closely together to develop our clients’ businesses through premier quality and expert execution. Our vision is to be the premier choice for companies when selecting a professional compliance and risk management service provider.

HOLT consultancy is growing and an opportunity has arisen for a Compliance Officer to join the team.

In order to be successful, applicants should meet the skills and experience detailed below. 

Applications will only be accepted from candidates who are currently or have been previously registered with the DFSA.

Responsibilities will include:

• Assisting clients in obtaining authorisation with the DFSA;
• Acting as the outsourced Compliance Officer and MLRO for DFSA Authorised Firms;
• Drafting and updating compliance and AML manuals, policies and procedures as well as compliance plans and compliance monitoring programmes;
• Delivering specialist training to clients on compliance, AML and corporate governance;
• Providing compliance and AML related advice to clients;
• Participating in ad-hoc Compliance and AML related projects;
• Keeping abreast of any changes in rules and regulations within the DIFC.

Desired skills and experience:

• At least 3-5 years of experience in a compliance role;
• Currently or previously registered with the DFSA;
• Detailed knowledge of DFSA rules and regulations;
• Very good knowledge of Investment Funds, Private Banking and Investment Banking;
• Strong written and verbal skills in English;
• The ability to work autonomously as well as within a team;
• Excellent interpersonal and relationship management skills;
• Self-directed with an ability to manage multiple tasks and to work under pressure;
• Degree educated.          

Candidates are invited to send a CV to info@holtconsultancy.com. Please ensure you include your contact details along with your current job status and, if relevant, your notice period.

To find out more about HOLT consultancy, our services and the team please visit our website at www.holtconsultancy.com.

HOLT consultancy LLC
Office 418

Liberty House

Dubai International Financial Centre
Dubai
United Arab Emirates

Email: info@holtconsultancy.com
Tel: +971 4 386 6360
Blog: www.holtconsultancy.blogspot.com
Website: www.holtconsultancy.com
Twitter: www.twitter.com/holtconsultancy

HOLT consultancy's Corporate Social Responsibility (CSR) Policy

HOLT consultancy is committed to operating with integrity, helping others and giving back to the community. To this end, it is our policy to actively engage in Corporate Social Responsibility activities in an effort to:

• promote education and enhance skills for employees, clients, university students and school children
• provide a safe working environment that promotes health and well-being
• support charities to improve the well-being of others
• manage the environmental impact of our business activities
• safeguard the reputation of the compliance industry and financial services sector

HOLT consultancy continually identifies CSR activities in line with our policy and encourages employees to participate.

Promoting Education and Skills

Employees - we want our employees to enjoy their work, feel challenged and have opportunities for development. To this end we have introduced Continuing Professional Development of 35 hours per year. This means our staff take time out to attend relevant conferences and events and sit professional exams, supported by HOLT consultancy.

Interns – we provide opportunities for a student with an interest in compliance to join us as a Compliance Intern to get involved in all aspects of our business.

Schools – HOLT consultancy are sponsors of the F1 in Schools initiative and take time out each year to help students to design, manufacture and test a compressed air powered balsa wood F1 car.

Clients – we want our clients to have a good reputation and have a good relationship with their regulator. We provide tools, training and mentoring that help our clients to understand the importance of maintaining stability within the financial sector through compliance and AML.

Supporting Health and Wellbeing

Helping others  - we want our employees to be able to help others in an emergency, should the need arise. To this end, our employees are trained in Heart Saver First Aid CPR and Fire Safety.

Staying healthy - exercise is important for the well-being of our employees. We actively encourage training and exercise and staff have access to a swimming pool and gym.

Fundraising - we encourage fund raising events, particularly those that involve exercise, e.g. football matches, marathons, walking, fun-runs. Our staff took part in the Standard Chartered marathon, Standard Chartered 10km walk and the 5km Darkness into Light walk for mental health awareness in 2017.

Donating and volunteering - DIFC regularly encourages firms in the DIFC to take part in its CSR initiatives and we are committed to supporting its ongoing efforts. In 2017 we were involved in the Eliminate the Thirst Campaign where we handed out bottles of water to workers around the DIFC area and the Donate Clothes for Humanity campaign where our team donated clothes and shoes.

Reducing our Environmental Impact

HOLT consultancy is a small company but understands that every company should take action to conserve energy and resources.

Our office policy requires staff to turn off PCs, monitors and printers at the end of each working day.

Our company recycles paper including shredded paper. This is collected by InfoFort who provide a free collection service through their GreenBox service.

We ask that staff keep printing to a minimum. 

If you can offer HOLT consultancy an opportunity to help you, please contact using

info@holtconsultancy.com.   

DFSA in Action 2017

The Dubai Financial Services Authority (DFSA) has pubished its DFSA in Action 2017 report. The highlights from the report are below.

As at 30 September 2017:

• 45 new licences issued. 
• 59 applications accepted. 
• 457 Authorised Firms regulated by the DFSA. 
• Regulatory oversight for 16 Registered Auditors, 119 Designated Non-Financial Businesses and Professions, 62 Recognised Members, 34 Reporting Entities and 2 Authorised Market Institutions.

Highlights

• The Dubai International Financial Centre (DIFC) has strongly emerged as a reinsurance hub for the Middle East and Africa benefitting from growing expertise, wider product offerings and increased underwriting capacity.
• There has been a rise in asset management applications.
• Funds activity in the DIFC has increased. The DFSA has processed 11 fund applications so far this year). The Qualified Investor Fund (QIF) regime attracted five Funds, four Exempt Funds and 2 Public Funds including a Real Estate Investment Trust listed on Nasdaq Dubai.
• In May the DFSA introduced the Innovation Testing Licence - a special class of financial services licence that allows FinTech firms to develop and test innovative concepts from the DIFC.
• In August the DFSA introduced a bespoke framework for loan and investment crowdfunding platforms (a first for the GCC).

Reports

The final report of the review of Client Classification and Suitability will be available this quarter. The main findings were:

• Failure to document client assessment in respect of client knowledge and experience.
• Failure to record the sub-category of Professional Client classification assigned to clients in accordance with Section 2 of the COB Rulebook Module. 

The final report of the financial crime thematic review will be available this quarter. The report highlighted the need to improve the quality of Business AML Risk Assessments and transaction monitoring frameworks. 

The outcome from the Survey of Authorised firms in the DIFC to better understand the risk arising from the use of cloud storage will be published soon. 

Consultation Papers issued

• Consultation Paper No. 109 Crowdfunding: SME Financing Through Lending
• Consultation Paper No.110 DFSA Fees (+ Feedback Statement on CP110 DFSA Fees)
• Consultation Paper No.111 Crowdfunding: SME Financing Through Investing
• Consultation Paper No.112 Testing Fintech Innovations in the DIFC 
• Consultation Paper No.113 Capital Requirements Review
• Consultation Paper No.114 Liquidity Requirements Review

HOLT consultancy can help you to set up in the DIFC and obtain a licence from the DFSA to operate as a regulated firm. Contact us now on info@holtconsultancy.com or call +9714 386 6360.

For more information about our services please visit www.holtconsultancy.com

DIFC Arts Night - November 2017

Dubai International Financial Centre (DIFC) held its biannual Arts Night on 1st November and some of the HOLT consultancy team attended. 



The event showcased installations from both local and international artists.  






Thank you to Mackline Martin for providing photographs of some of the installations for our post.

HOLT consultancy is recruiting for a Compliance Officer

Compliance Officer

HOLT consultancy LLC is an award winning professional compliance and risk management service provider, based in the DIFC. It was established in 2012 and this year celebrates its 5th anniversary. Its reputation within the DIFC has attracted some large clients who require expertise in licence applications and outsourced Compliance Officer and Money Laundering Reporting Officer (MLRO) services.

We are a friendly team who work closely together to develop our clients’ businesses through premier quality and expert execution. Our vision is to be the premier choice for companies when selecting a professional compliance and risk management service provider.

HOLT consultancy is growing and an opportunity has arisen for a Compliance Officer to join the team.

In order to be successful, applicants should meet the skills and experience detailed below. 

Applications will only be accepted from candidates who are currently or have been previously registered with the DFSA.

Responsibilities will include:

• Assisting clients in obtaining authorisation with the DFSA;
• Acting as the outsourced Compliance Officer and MLRO for DFSA Authorised Firms;
• Drafting and updating compliance and AML manuals, policies and procedures as well as compliance plans and compliance monitoring programmes;
• Delivering specialist training to clients on compliance, AML and corporate governance;
• Providing compliance and AML related advice to clients;
• Participating in ad-hoc Compliance and AML related projects;
• Keeping abreast of any changes in rules and regulations within the DIFC.

Desired skills and experience:

• At least 3-5 years of experience in a compliance role;
• Currently or previously registered with the DFSA;
• Detailed knowledge of DFSA rules and regulations;
• Very good knowledge of Investment Funds, Private Banking and Investment Banking;
• Strong written and verbal skills in English;
• The ability to work autonomously as well as within a team;
• Excellent interpersonal and relationship management skills;
• Self-directed with an ability to manage multiple tasks and to work under pressure;
• Degree educated.          

Candidates are invited to send a CV to info@holtconsultancy.com. Please ensure you include your contact details along with your current job status and, if relevant, your notice period.

To find out more about HOLT consultancy, our services and the team please visit our website at www.holtconsultancy.com.

HOLT consultancy LLC
Office 418

Liberty House

Dubai International Financial Centre
Dubai
United Arab Emirates

Email: info@holtconsultancy.com
Tel: +971 4 386 6360
Blog: www.holtconsultancy.blogspot.com
Website: www.holtconsultancy.com
Twitter: www.twitter.com/holtconsultancy

HOLT consultancy celebrates its 5th anniversary

Since 30 October 2012 when Ben Holt, CEO established HOLT consultancy, it has achieved significant growth in size, services offered and reputation.

The company has grown to a team of 9 professionals with experience ranging from private banking, asset management, (re)insurance, corporate finance and more, which means HOLT consultancy is best placed to match the experience of the team member to the type of client.  

In 2014, HOLT consultancy won the award for Best Consulting Firm of the Year at the Thomson Reuters Governance, Risk and Compliance Awards, 8th GCC Regulators Summit in Dubai. 

Its reputation within the DIFC has attracted some large clients who require expertise in licence applications and outsourced Compliance Officer and Money Laundering Reporting Officer services.

HOLT consultancy’s clients include (re)insurance companies, companies providing asset management, wealth management, private banking, investment banking (M&A, corporate and project finance, trading, research etc) and the funds businesses.  

Main offerings of HOLT consultancy    

1. Applications and authorisation – providing assistance with the licence application process for companies seeking to set up in the DIFC (both non-regulated as well as regulated companies).
2. Compliance support - being a retained outsourced Compliance Officer/MLRO or mentoring new or less experienced Compliance Officers/MLROs.
3. Compliance reviews – these could be focused on a specific area of the business or a general health check to assess whether a firm’s systems and controls are functioning as they should.
4. Drafting Compliance Manuals, Anti Money Laundering Manuals, policies, procedures and designing systems and controls to mitigate risk.
5. Training – they assist clients in providing a wide range of regulatory, Compliance and Anti-Money Laundering & Counter Terrorist Financing related training.

Ben Holt, CEO said “We want to say thank you to our clients, the DFSA and the DIFC who have worked with us over the past 5 years. Our close relationships with all stakeholders means that HOLT consultancy can truly add value to their business. I would also like to thank all HOLT consultancy employees for their professionalism and commitment over the past 5 years” 

HOLT consultancy’s vision is to be the premier choice for companies when selecting a professional compliance and risk management service provider.

HOLT’s mission is to develop their client's business through premier quality and expert execution by focusing on their needs and providing business solutions. They strive to offer a service that exceeds expectations through its commitment to clients, adding maximum value to their business and protecting their reputation.

If HOLT consultancy can help you meet your compliance requirements, please contact us by email using info@holtconsultancy.com or call +971 4 386 6360.