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Compliance in the DIFC

Compliance in the DIFC

The following article was published on the Business Inside Reporter website as part of its CEO Reports 2017 Middle East Region feature.


To read other CEO Reports, please visit 


Ben Holt started HOLT consultancy in October 2012 after 8 years of working as Head of Compliance in the MENA region for HSBC, Societe Generale and latterly Barclays. He could see there was a gap in the market for a high quality, niche compliance consulting firm, one which was smaller with a sole focus to put the needs of clients above all else. This is when he thought of creating a firm which was flexible enough to react to the unique situations which regulated firms in the DIFC can sometimes find themselves in and be able to respond dynamically and provide meaningful assistance. Over the past four and a half years, HOLT consultancy’s reputation in the market is testimony to the fact that they have been able to achieve this and add real value to their client’s business.


Central to HOLT consultancy’s success has been recruiting and retaining some fantastic people. A company is nothing if it does not have the right staff in place to deliver its mission and that is something Ben believes in passionately. His vision was to recruit two senior compliance experts who would each lead a team in different industry sectors. Shamshad Khan looks after the investment banking/private banking/funds/asset management side while Natalie Hodgins specialises in (re)insurance. Both seniors have managed to recruit some absolutely stand-out consultants and their efforts combined are what makes HOLT consultancy not only a fun and enjoyable workplace but also one which delivers a quality, value added service to its clients.


Earlier in 2017, HOLT consultancy took the strategic decision to join the DIFC Insurance Association. HOLT consultancy provides advice and outsourced compliance services to a number of DIFC based (re)insurance firms. So, joining a professional body like the DIFC Insurance Association would enable HOLT consultancy to represent the best interests of their clients in a market that continues to grow and mature.


Even at the early stages of HOLT consultancy’s existence, its successful approach to business meant that HOLT consultancy was awarded the 2014 Best Consulting Firm of the Year at the Thomson Reuters Governance, Risk and Compliance Awards, 8th GCC Regulators Summit in Dubai.


Ben says “We are a relatively small firm. I purposely want to retain it at about the size it is now, possibly recruiting two or three additional consultants. I believe that keeping the firm at this size enables both myself as CEO and Shamshad and Natalie as seniors to retain effective oversight of everything which is happening and means that we can keep a good level of interaction from the top with all of our clients”.


Delivering a top-down service is essential to the success of HOLT consultancy. When employing one of its consultants, firms also buy the senior management team as they take relationship-building and ongoing maintenance extremely seriously. “How can I, as CEO, understand the nature of a problem a consultant may bring me if I do not know the dynamics of the client for whom they are working? It also demonstrates to clients that HOLT consultancy, as a whole, is committed to delivering a truly stand-out, value add compliance service” comments Ben.


He says recruitment is sometimes a significant challenge. Finding the right people with the right experience and knowledge of the DIFC/DFSA rules and regulations and with relevant qualifications can sometimes be problematic. They are always looking at the market for good quality candidates that can not only add real value to the HOLT consultancy business but also to its clients.


The companies vision is very simple. They want 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.


Main offerings of HOLT consultancy


1. Applications and authorisation – they provide 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.


Their clients range from (re)insurance companies to companies providing asset management, wealth management, private banking, investment banking (M&A, corporate and project finance, trading, research etc) and the funds business. Effectively, the primary target is all financial services which are regulated by the Dubai Financial Services Authority (DFSA) in the DIFC.


Diversity and experience of their team – HOLT consultancy has employees who have experience ranging from private banking, asset management, insurance, corporate finance etc. They try to match the experience of the team member to the type of client, which results in the client being happy with the service they receive.


Their consultants all have something different to offer and a large part of that shines through in their unique personalities. As Ben reiterates “relationships are at the centre of everything we do and our consultants are the focal point for nurturing and cementing these relationships with the people who are the face of our clients. I will not employ anyone I cannot engage with and relate to because if I can’t then the chances are HOLT consultancy clients will not either and that is not good for either party.”


HOLT consultancy is constantly looking towards innovation to enhance and develop their processes and procedures. They want to match the pace of change in this part of the world, thereby helping to facilitate change on behalf of its clients. This is exemplified by developments in the DIFC such as the FinTech Hive and Innovation Testing License which the DFSA has developed to allow qualifying FinTech firms to develop and test innovative concepts from within the DIFC, without being subject to all the regulatory requirements that normally apply to regulated firms.


“We have introduced a greater element of automation into the way in which we work and I see this only increasing in the future as regulation itself becomes more automated” Ben concluded.


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