We get firms licensed in the DIFC and ADGM, and then we stay: as their Compliance Officer, MLRO, Finance Officer or Risk Officer, in the room when the regulator calls. Advice that is specific to your firm, written by people who have sat across the table from the DFSA and FSRA.
Most clients start with one and end up using all three. Each page tells you exactly what is included.
The Regulatory Business Plan, the financial model, the forms, the framework and the conversations with the regulator, from the first category assessment to In-Principle Approval. DFSA, FSRA, funds, fintech and DNFBP registrations.
How a licence application works
Outsourced Compliance Officer and MLRO, the monitoring programme, the annual reviews, the training, the returns and the filings. Our people are approved by the regulator for your firm and answer to your board.
What an outsourced function includes
Outsourced Finance Officer and Risk Officer, prudential returns, VAT and corporate tax, business risk assessments, and independent internal audit that tells you what the regulator would find before the regulator does.
Finance, risk and audit in detailPick the one that sounds like you. We'll show you what we would do first.
Category, activities, capital and the people you will need to name. Then we build the application around a business plan the regulator can actually follow. The first submission decides the timetable, so we do not rush it.
See how we run an application
Your manual, your last monitoring reports, your last exchange with the regulator. Then we tell you what is fine, what is missing and what we would fix in the next ninety days. If you want us to take the Compliance Officer or MLRO role, that is where the plan starts.
See our outsourced functions
A new activity, a second centre, an acquisition or a group framework arriving from head office: each one touches the licence, and the regulator wants to hear about it in a particular sequence. We map that sequence, and then we carry the paperwork.
See our advisory work
Primo started in the DIFC in December 2022 with a simple idea: regulated firms in the UAE deserve advice that is specific to them, not a template with the name changed. We opened in the ADGM in 2025, merged with Artemis Consultancy that autumn, and we have grown on client referrals alone, with no outside capital. The people you meet at the first conversation are the people who do the work.
Meet the people and read the storyThree things we hold ourselves to on every mandate. Hover over each one.
The consultant you meet is the one the regulator approves and the one who does the work. No account managers, no hand-offs.
Frameworks written around how your business actually operates, not a template with the name changed. If it would not survive an inspection, we do not write it.
We would rather tell you something you do not want to hear in week one than have the regulator tell you in month six.
A short call is usually enough to tell you whether we can help and what it would take. No slide deck, no obligation.
Talk to usFive things, listed below in full. Some clients take one, most end up with two or three, and a few hand us the whole compliance, finance and risk function. Whichever it is, the person you meet is the person the regulator approves and the person who does the work.
Three steps. The third is the one that matters, and it is the one most firms never get to see before they sign.
Half an hour, usually. You tell us what the business does and where it is going. We tell you what the DFSA or FSRA will want to see, what is realistic and what is not. If we are not the right fit, we say so.
What we will do, who will do it, when, and what we need from you. Written so your board can read it in five minutes. No surprises later, in either direction.
The consultant who is approved by the regulator for your firm is the one who reads your files, sits in your board meetings and picks up the phone when the regulator calls. You will know their name from day one.
If the Compliance Officer for your UAE entity sits in London, Zurich or Singapore, the regulator still expects someone to know what is happening in Dubai or Abu Dhabi this week. We are often that someone.
From a two-person advisory boutique to a fund manager with a listed parent. The rules are the same; how you apply them is not.
A short call is usually enough to tell you whether we can help and what it would take. No slide deck, no obligation.
Talk to usNico and Ward are the names on the door, but the work is done by a team that has grown one hire at a time, each of them approved by the DFSA or the FSRA for the function they hold at a client. Nobody at Primo is "on the account"; they are the Compliance Officer, or the MLRO, or the Finance Officer, with their name on the regulator's register and their phone number on your speed dial.
We deliberately keep the client list to a size where every consultant knows every file they are responsible for. When a client outgrows what one person can carry, we add a person, not a process.
Working at Primo
Central Park Towers, Office Tower, Level 17, Unit 17-39
DIFC, PO Box 507267, Dubai, United Arab Emirates
Sky Tower, Unit 3701-08 - D9, Al Reem Island
ADGM, Abu Dhabi, United Arab Emirates
Every month we read what the DFSA, the FSRA and the UAE authorities have published, and write down what happened, why it matters and what a firm like yours should do about it. Nothing here is sales copy; it is the same note our own Compliance Officers work from.
Write a line about your firm and where it is on its regulatory journey, and one of us will come back to you. Not a call centre, not a chatbot: Nico, Ward or the consultant who will actually do the work.
info@primoadvisors.com · +971 4 340 0378
Central Park Towers, Office Tower, Level 17, Unit 17-39
DIFC, PO Box 507267, Dubai, United Arab Emirates
Sky Tower, Unit 3701-08 - D9, Al Reem Island
ADGM, Abu Dhabi, United Arab Emirates
Thirteen of us, in Dubai and Abu Dhabi, each holding a regulator-approved function at the firms we look after. It is a small team by design, so when we hire, we hire carefully and we hire for the long run. Two roles are open now.
Every vacancy we have is on this page. Read the whole card before you apply; the items in bold are not negotiable.
You will hold the Finance Officer function for FSRA-regulated client firms, in your own name, and be the person the regulator and the client's board look to for the numbers.
You will run client onboarding and periodic reviews for the firms where Primo holds the MLRO function, and keep the DIFC office running.
You will hold regulator-approved functions in your own name at DFSA-regulated client firms, most often as Compliance Officer and MLRO, and be the person the client's board and the regulator call.
A short form, then an email. We read every application that answers the questions; we do not read the ones that don't.
A regulator-approved Compliance Officer who holds the function for your firm, with a team behind them. For firms that need the role done properly, not a full-time hire.
Asset and fund managers, advisers, brokers, family offices and fintechs in the DIFC and ADGM. Also firms that need cover during recruitment or a transition.
An outsourced MLRO, the Finance Officer function and the annual internal audit. One provider, one framework, one contact for the regulator.
We read your licence, business plan and current framework.
We apply to the regulator for the Compliance Officer authorisation.
A calendar agreed with management, reported to the Board.
A second consultant is named from day one.
Our consultants hold Compliance Officer, MLRO, Finance Officer and Risk Officer functions at DIFC and ADGM firms today, so they deal with the regulator every week. One firm, offices in both centres.

Tell us what your licence covers and we will set out how we would run the function for you.
Talk to usWe prepare and manage your DFSA application from the first scoping call to the licence, from our office in the DIFC.
Asset and fund managers, advisers and arrangers, brokers, corporate finance firms, family offices and fintechs. Firms moving a regulated activity into the DIFC, and firms choosing between the DIFC and ADGM.
An RBP that does not match the forms, people whose experience does not fit the function, capital that cannot be evidenced, or a framework copied from another firm. We close those questions before the DFSA asks.
Category, activities and people agreed before anything is written.
The RBP, projections and controls in the form the DFSA expects.
AUT-CORE, AUT-IND and the compliance framework.
Pre-application meeting, review questions and approval conditions.
Most firms we license keep us on as Compliance Officer and MLRO, so the team that wrote the framework is the team that runs it. Our consultants are DFSA authorised individuals at DIFC firms today.

Send us a short description of the business and we will tell you which category fits and what the application needs.
Talk to usWe prepare and manage your Financial Services Permission application from our ADGM branch, with the team that holds compliance functions at ADGM firms.
Category 1 (deposit-taking) to Category 4 (advising and arranging), with 3A, 3B and 3C for dealing, custody and managing assets or funds. The category sets the capital, the prudential rules and the Controlled Functions. We settle it with you first.
Fund and venture capital managers, asset managers, advisers, brokers, corporate finance firms, family offices and fintechs. Groups regulated in the UK, EU, Singapore or Hong Kong adding an ADGM entity.
Activities, category and the ADGM-or-DIFC question, settled first.
Business model, governance, projections and controls.
FSP form, Approved Person forms, controllers and policies.
Pre-application meeting, review queries and approval conditions.
Most firms we license keep us on as Compliance Officer and MLRO, and Finance Officer where the category needs one. Our consultants are FSRA Approved Persons at ADGM firms and DFSA authorised individuals at DIFC firms, from one firm with offices in both centres.

Tell us the activities you intend to carry on and we will set out the category, the application and the timeline.
Talk to usThe UAE Capital Market Authority, formerly the SCA, licenses financial activities on the UAE mainland. We prepare and manage the application, and we know how it differs from a DFSA or FSRA one.
The Capital Market Authority replaced the Securities and Commodities Authority on 1 January 2026. It regulates securities, commodities and investment activities onshore in the UAE, outside the DIFC and ADGM.
Brokers, financial advisers and consultants, promoters of foreign funds and securities, fund managers and fintechs that need to serve clients on the UAE mainland. Also DIFC and ADGM firms adding an onshore permission.
Category, activities and the onshore-or-free-zone question, settled first.
Forms, business plan, financial projections and the policies the CMA asks for.
Queries during review and the conditions before approval.
Approval conditions evidenced, then the compliance function begins.
Many firms weigh a CMA licence against a DFSA or FSRA one, or need both. We work under all three regimes from one firm, so the comparison is honest and the frameworks line up.

Tell us the activities you intend to carry on and who your clients are, and we will say which regime fits and what the application needs.
Talk to usThe authorised individual who owns your prudential compliance: the capital you must hold, the returns you must file, and the notifications before a problem becomes a breach.
We do not replace your bookkeeper, accountant or auditor. We work from the accounts they produce and take responsibility for what the regulator sees. Where a firm has no finance function, we can combine the role with outsourced accounting.
Category 3C and 4 firms with expenditure-based capital; Category 3A firms that need the risk-based calculation done properly; fund managers with client money; and group entities whose finance team is abroad.
Your category, capital base and current reporting set-up.
We apply for the Finance Officer authorisation.
Return deadlines and capital checks on a fixed schedule.
Returns filed, capital position reported to the Board.
Our Finance Officers hold the function at DFSA and FSRA firms today and file returns every quarter. They sit alongside our Compliance Officers and MLROs, so a change to the business is assessed for compliance, AML and prudential effect at once.

Tell us your category and how your finance function is set up today and we will say how we would hold the role for you.
Talk to usBoth regulators expect an internal audit function that is independent of compliance and the business. For most Category 3 and 4 firms that means outsourcing it. We provide it, with findings a Board can act on.
The report goes to the Board. Each finding names the document and version it relates to, is rated, and says what would close it. We confine findings to matters of regulatory substance, not typographical or version-control points.
Where Primo already holds the Compliance Officer or MLRO function at a firm, the internal audit is done by a separate team with no involvement in the functions audited, as the rules intend.
Agreed from your licence and risk profile.
Document review, sample testing and interviews.
Findings discussed with management before they are final.
Final report with ratings and actions.
Our auditors hold Compliance Officer, MLRO and Finance Officer functions at other DIFC and ADGM firms, so they audit against what the regulators are examining this year. Written for a Board, in plain language.

Tell us when your last internal audit was and what your licence covers, and we will propose the scope and timing.
Talk to us