Stay up to date with our latest news
As financial institutions operating in the UAE face increasing scrutiny from regulators, the Central Bank of the UAE (CBUAE) has elevated its supervisory toolkit to ensure licensed firms are meeting compliance expectations. Among its key instruments is the Skilled Persons Review (SPR) regime, designed to independently assess firms' adherence to regulatory obligations. For regulated entities, understanding SPRs is no longer optional. It is essential to prepare, respond and remediate effectively.
What is a Skilled Persons Review?
A Skilled Persons Review is a formal assessment mandated by the CBUAE under Article 137 of the Decretal Federal Law No. (14) of 2018. The CBUAE may appoint a third-party expert — typically a qualified consultancy or legal firm — to conduct an in-depth review of a regulated entity’s systems, controls, governance or risk frameworks. The objective is to provide the regulator with a transparent, independent view of compliance effectiveness in specific operational areas.
These reviews are generally triggered by supervisory concerns, off-site monitoring, thematic inspections or regulatory developments. They can focus on areas such as AML compliance, internal audit, board governance or consumer protection — depending on where gaps or risks have been identified.
While not every firm will be subject to a Skilled Persons Review, the trend is clear. CBUAE is increasing its reliance on SPRs to complement its supervisory mandate.
Why CBUAE is Turning to SPRs More Often
The SPR regime reflects a broader global movement toward accountability and independent assurance in financial regulation. In the UAE, this trend has intensified since the country’s removal from the Financial Action Task Force (FATF) grey list in 2024. In a statement earlier this year, the CBUAE emphasised that “robust, risk-based supervision remains central to maintaining financial stability and investor confidence.”
Recent data points to this increased emphasis. According to the UAE Financial Stability Report 2023, more than 30 independent reviews were commissioned across banking and insurance sectors last year alone. The number is expected to rise by 20 percent in 2025, driven by enhanced risk sensitivity and greater regulatory pressure across the financial ecosystem.
What Triggers a Skilled Persons Review?
The CBUAE may initiate an SPR under several scenarios:
Concerns raised through supervisory inspections
Gaps identified in AML or financial crime frameworks
Weaknesses in internal audit or governance reporting lines
Breaches in conduct or risk reporting obligations
Events involving operational disruption, cyber risk or regulatory breaches
According to a senior compliance leader at a UAE commercial bank:"The skilled persons process is not just about catching failure. It’s about establishing an objective understanding of what ‘good’ looks like in the UAE’s regulatory environment."
The scope of the review is typically detailed in the CBUAE’s appointment letter and may involve on-site interviews, document requests, system walkthroughs and root cause analysis. The process can take several weeks to several months depending on complexity.
Are SPRs Mandatory?
Yes, if the CBUAE mandates a review, compliance is compulsory. Firms must cooperate fully with the appointed skilled person and provide access to relevant documents, systems and personnel. The final report is submitted to the CBUAE and may include required remediation actions with timelines.
There is no fixed frequency for SPRs. However, firms with persistent control issues or heightened risk exposure may be subject to follow-up reviews or broader inspections. In the words of a former central bank regulator, now advising financial institutions:"SPRs are a signal. They highlight where the regulator expects accountability and rigour. Firms that treat them as a checklist exercise are missing the point."
Strategic Implications for Regulated Firms
Firms subject to an SPR must act swiftly but strategically. The implications go beyond the findings — the regulator may assess the tone of response, the leadership's involvement, and the credibility of remediation. It is not unusual for SPR outcomes to be referenced in future supervisory reviews or enforcement decisions.
Failure to engage constructively can lead to sanctions or reputational damage. On the other hand, firms that use the process to demonstrate transparency and resilience often find themselves in stronger regulatory standing.
It is also important to note that while the skilled person is appointed by the CBUAE, the cost of the review is borne by the regulated entity. Planning ahead, allocating internal resources, and securing expert support is essential.
How j. awan & partners Can Support
j. awan & partners has deep experience advising financial institutions subject to Skilled Persons Reviews. Our regulatory advisory teams support clients throughout the SPR lifecycle — from readiness assessments and documentation support to stakeholder management and remediation planning.
Our services include:
SPR scoping and gap assessments
Liaison and communication with appointed skilled persons
Audit trail and policy alignment review
Response strategy and remediation roadmap development
Post-review reporting and supervisory engagement support
We bring the local insight, sector familiarity and regulatory fluency needed to ensure SPRs are approached not just as a compliance requirement, but as a strategic opportunity for uplift.
Conclusion
In a supervisory environment where transparency and independent assurance are paramount, Skilled Persons Reviews are becoming a defining feature of regulatory oversight in the UAE. For financial institutions, this means more than meeting the minimum bar. It means preparing for scrutiny, demonstrating maturity, and turning review into resilience.
j. awan & partners stands ready to support firms navigating this critical process.
Get in touch to explore how we can support your institution through a Skilled Persons Review or broader regulatory advisory needs.
Email: info@jawanpartners.com | Visit: jawanpartners.com
Navigating CBUAE Skilled Persons Reviews: What Regulated Firms Need to Know
With rising regulatory expectations in the UAE, the Central Bank’s Skilled Persons Review (SPR) is now a key supervisory tool. This article explores its purpose, process, and impact, and how j. awan & partners support firms throughout the review.
Navigating CBUAE Skilled Persons Reviews: What Regulated Firms Need to Know
With rising regulatory expectations in the UAE, the Central Bank’s Skilled Persons Review (SPR) is now a key supervisory tool. This article explores its purpose, process, and impact, and how j. awan & partners support firms throughout the review.
As financial institutions operating in the UAE face increasing scrutiny from regulators, the Central Bank of the UAE (CBUAE) has elevated its supervisory toolkit to ensure licensed firms are meeting compliance expectations. Among its key instruments is the Skilled Persons Review (SPR) regime, designed to independently assess firms' adherence to regulatory obligations. For regulated entities, understanding SPRs is no longer optional. It is essential to prepare, respond and remediate effectively.
What is a Skilled Persons Review?
A Skilled Persons Review is a formal assessment mandated by the CBUAE under Article 137 of the Decretal Federal Law No. (14) of 2018. The CBUAE may appoint a third-party expert — typically a qualified consultancy or legal firm — to conduct an in-depth review of a regulated entity’s systems, controls, governance or risk frameworks. The objective is to provide the regulator with a transparent, independent view of compliance effectiveness in specific operational areas.
These reviews are generally triggered by supervisory concerns, off-site monitoring, thematic inspections or regulatory developments. They can focus on areas such as AML compliance, internal audit, board governance or consumer protection — depending on where gaps or risks have been identified.
While not every firm will be subject to a Skilled Persons Review, the trend is clear. CBUAE is increasing its reliance on SPRs to complement its supervisory mandate.
Why CBUAE is Turning to SPRs More Often
The SPR regime reflects a broader global movement toward accountability and independent assurance in financial regulation. In the UAE, this trend has intensified since the country’s removal from the Financial Action Task Force (FATF) grey list in 2024. In a statement earlier this year, the CBUAE emphasised that “robust, risk-based supervision remains central to maintaining financial stability and investor confidence.”
Recent data points to this increased emphasis. According to the UAE Financial Stability Report 2023, more than 30 independent reviews were commissioned across banking and insurance sectors last year alone. The number is expected to rise by 20 percent in 2025, driven by enhanced risk sensitivity and greater regulatory pressure across the financial ecosystem.
What Triggers a Skilled Persons Review?
The CBUAE may initiate an SPR under several scenarios:
Concerns raised through supervisory inspections
Gaps identified in AML or financial crime frameworks
Weaknesses in internal audit or governance reporting lines
Breaches in conduct or risk reporting obligations
Events involving operational disruption, cyber risk or regulatory breaches
According to a senior compliance leader at a UAE commercial bank:"The skilled persons process is not just about catching failure. It’s about establishing an objective understanding of what ‘good’ looks like in the UAE’s regulatory environment."
The scope of the review is typically detailed in the CBUAE’s appointment letter and may involve on-site interviews, document requests, system walkthroughs and root cause analysis. The process can take several weeks to several months depending on complexity.
Are SPRs Mandatory?
Yes, if the CBUAE mandates a review, compliance is compulsory. Firms must cooperate fully with the appointed skilled person and provide access to relevant documents, systems and personnel. The final report is submitted to the CBUAE and may include required remediation actions with timelines.
There is no fixed frequency for SPRs. However, firms with persistent control issues or heightened risk exposure may be subject to follow-up reviews or broader inspections. In the words of a former central bank regulator, now advising financial institutions:"SPRs are a signal. They highlight where the regulator expects accountability and rigour. Firms that treat them as a checklist exercise are missing the point."
Strategic Implications for Regulated Firms
Firms subject to an SPR must act swiftly but strategically. The implications go beyond the findings — the regulator may assess the tone of response, the leadership's involvement, and the credibility of remediation. It is not unusual for SPR outcomes to be referenced in future supervisory reviews or enforcement decisions.
Failure to engage constructively can lead to sanctions or reputational damage. On the other hand, firms that use the process to demonstrate transparency and resilience often find themselves in stronger regulatory standing.
It is also important to note that while the skilled person is appointed by the CBUAE, the cost of the review is borne by the regulated entity. Planning ahead, allocating internal resources, and securing expert support is essential.
How j. awan & partners Can Support
j. awan & partners has deep experience advising financial institutions subject to Skilled Persons Reviews. Our regulatory advisory teams support clients throughout the SPR lifecycle — from readiness assessments and documentation support to stakeholder management and remediation planning.
Our services include:
SPR scoping and gap assessments
Liaison and communication with appointed skilled persons
Audit trail and policy alignment review
Response strategy and remediation roadmap development
Post-review reporting and supervisory engagement support
We bring the local insight, sector familiarity and regulatory fluency needed to ensure SPRs are approached not just as a compliance requirement, but as a strategic opportunity for uplift.
Conclusion
In a supervisory environment where transparency and independent assurance are paramount, Skilled Persons Reviews are becoming a defining feature of regulatory oversight in the UAE. For financial institutions, this means more than meeting the minimum bar. It means preparing for scrutiny, demonstrating maturity, and turning review into resilience.
j. awan & partners stands ready to support firms navigating this critical process.
Get in touch to explore how we can support your institution through a Skilled Persons Review or broader regulatory advisory needs.
Email: info@jawanpartners.com | Visit: jawanpartners.com