Every SFC-licensed corporation must maintain a compliance function appropriate to its size and business. Smaller and newly-licensed firms often do not want — or cannot justify — a full in-house compliance team on day one. Outsourcing the function to a specialist is an established way to meet the standard without building the whole department yourself.
The important principle is that outsourcing moves the work, not the accountability. The licensed corporation and its senior management remain responsible to the SFC for compliance. A good outsourced arrangement is built so that responsibility is properly discharged, evidenced and overseen — not quietly dropped.
What a firm can outsource
The day-to-day compliance workload is what typically moves to a specialist provider, under the firm’s oversight.
- Ongoing compliance advisory and regulatory-change monitoring.
- Compliance manuals, policies and procedures — drafting and keeping them current.
- Regulatory filings and returns, prepared and submitted on time.
- AML/CFT programme operation — CDD reviews, monitoring and reporting support.
- SFC inspection preparation and support.
- Money Laundering Reporting Officer (MLRO) and compliance-officer support functions.
Where responsibility stays
Under the SFC’s expectations on outsourcing, the licensed corporation remains responsible for the outsourced function. Senior management must exercise proper oversight of the provider, retain the ability to access records and information, and be able to demonstrate that the arrangement is working. Outsourcing is a delivery model — it does not transfer the regulatory obligation.
What a compliance-as-a-service engagement looks like
A well-structured engagement starts with a review of the firm’s current framework and obligations, sets a clear scope of what the provider owns versus what stays in-house, and runs on a defined cadence — routine monitoring and filings, periodic reviews, and escalation when something needs the firm’s decision. The firm gets a running compliance function and a documented trail; the provider carries the load.
When to outsource, and when to build
Outsourcing suits firms that need a credible function quickly, want senior compliance judgement without a full-time hire, or need surge support around a licence, an inspection or a remediation. As a firm grows, the model often shifts — a hybrid where a lean in-house team is backed by the specialist, and eventually a fuller internal function. The right answer depends on the firm’s size, activity and risk.
What we do on outsourced compliance.
- Review your current compliance framework against your SFC obligations.
- Take on the compliance function wholesale — compliance-as-a-service — or support a lean in-house team.
- Run ongoing advisory, manuals, filings and AML operation on a defined cadence.
- Prepare for and support SFC on-site inspections.
- Keep the documented oversight trail senior management needs to evidence the arrangement.
Frequently asked
Is outsourcing compliance allowed for an SFC-licensed firm?
Yes. Firms may outsource compliance activities, but the licensed corporation remains responsible to the SFC for the function and must properly oversee the provider. The arrangement is built to keep that responsibility evidenced.
Can you act as our MLRO or compliance officer?
RETU provides outsourced compliance support functions and runs the day-to-day compliance workload. Where a role must be held by an approved individual, that is arranged within the regulatory framework, with the firm retaining accountability.
How is outsourced compliance priced?
Typically as a retained engagement scoped to your size, regulated activity and workload — routine monitoring and filings on a cadence, with defined support around inspections or projects. It is scoped after a review of your obligations.
Does outsourcing mean we can stop thinking about compliance?
No — and any provider who implies otherwise is wrong. Senior management keeps the regulatory responsibility and the oversight duty. Outsourcing removes the workload and adds expert judgement; it does not remove accountability.
RETU Consulting Limited is a financial-services consultancy and is not itself an SFC-licensed corporation. Where an engagement involves a regulated activity, that activity is carried out by the appropriately licensed entity.