Nadenne Adame

Outsourced compliance advisory function leading multi-regulator engagements across VARA, CMA/SCA, CBUAE,
MOE/DNFBP, DFSA, and ADGM frameworks.
▸ Serve as named outsourced Compliance Officer / MLRO for regulated client entities — accountable for goAML
STR/SAR reporting, IEMS directive monitoring, sanctions screening oversight, and board-level compliance
reporting.
▸ Led VARA licensing compliance remediation engagements for VARA-licensed clients — closing multiple
documentation and policy gaps across AML/CFT frameworks, risk scoring methodologies, and operational
procedures aligned to the VARA CRM Rulebook v2.0 and Federal Decree-Law No. 10 of 2025.
▸ Advised VARA-licensed clients through Tier 1 UAE banking relationship applications — producing targeted
policy updates, documentation remediation, and financial crime compliance responses to address due
diligence requirements.
▸ Built full compliance frameworks from the ground up across multiple regulated client entities — AML/CFT
policy manuals, Compliance Monitoring Programmes, Sanctions Compliance Policies, Client Risk Assessment
methodologies, PEP / SAR / UBO / EDD registers, KYC onboarding form suites, Business Continuity Plans, and
Conflict of Interest policies.
▸ Advised CMA/SCA-regulated firms through the SCA-to-CMA regulatory transition, delivering updated
compliance frameworks and client documentation suites aligned to Federal Law No. 10 of 2025 and Cabinet
Resolution No. 134 of 2025.
▸ Supported VARA-licensed clients with compliance framework uplifts — incorporating client categorisation
under the VARA Market Conduct Rulebook Part IV and scoping Appropriateness Assessment obligations to
retail clients.
▸ Built a multi-regulator compliance report taxonomy covering mandatory report types across CMA/SCA, VARA,
CBUAE, MOE/DNFBP, and DFSA/FSRA — mapping regulatory basis, minimum requirements, and submission
deadlines into a structured reference platform.
▸ Conducted inspection-readiness internal audits for UAE DNFBP and CSP clients — authoring prioritised
remediation action plans across multiple compliance workstreams and managing findings through to closure.
▸ Acted as Lead Internal Auditor on a cross-brand internal audit spanning a multi-entity group, producing the full
findings report and overseeing remediation closure across all workstreams.
▸ Served as Internal Auditor for ISO 27001 and ISO 22301 certification programmes, conducting internal audits,
evidence validation, control testing, remediation tracking, and certification readiness assessments that
contributed to successful certification outcomes.
▸ Designed and delivered a structured junior Compliance Officer training programme — covering VARA,
CMA/SCA, and DNFBP compliance disciplines — to support internal capability development.
▸ Built modular compliance advisory pricing infrastructure covering all five UAE regulators across retainer,
cybersecurity, and platform service tiers.

Regulator-side AML/CFT supervisory role conducting inspections of licensed DNFBPs under UAE Federal AML law
and Ministry of Economy supervisory guidance.
▸ Led end-to-end AML/CFT inspections of licensed DNFBPs — document review, on-site examination, risk-based
findings reporting, and enforcement follow-up — applying the supervisory framework under Federal Decree
Law No. 20 of 2018 (as amended).
▸ Conducted UBO compliance reviews and drove enforcement actions against non-compliant licensees, directly
improving UBO declaration rates and entity transparency across the free zone.
▸ Managed supervisory interactions with regulated entities — responding to regulatory queries, issuing
corrective action requirements, and tracking remediation plans through to closure.
▸ Identified systemic compliance gaps at licensee and sector level, feeding findings into the free zones
inspection framework, supervisory reporting systems, and risk-based monitoring processes.
▸ Delivered AML/CFT training and regulatory guidance to licensees, translating complex UAE Federal obligations
into practical, operational compliance requirements.

▸ Conducted sanctions and payment screening across retail banking and trade finance flows at one of the UAEs
largest banking groups.
▸ Reviewed outbound and inbound payment messages, trade finance instruments (LCs, guarantees,
documentary collections), and customer transactions against OFAC, UN, EU, UK, and UAE TFS sanctions lists.
▸ Triaged and dispositioned sanctions alerts in line with CBUAE AML/CFT obligations, the banks risk appetite,
and internal escalation protocols — escalating confirmed matches through to compliance decisioning.
▸ Contributed to screening rule calibration, reducing false positives and improving alert quality across retail and
trade finance channels.

Group-level compliance leadership across a multi-business-line DNFBP group: corporate service provider, real
estate brokerage, vault and safe deposit locker services, and banking consultancy.
▸ Built and operationalised a group-wide AML/CFT compliance framework across four regulated business lines
— each with distinct risk profiles under UAE Federal AML law, Ministry of Economy DNFBP guidance, Dubai
Land Department / RERA obligations, and FATF 40 Recommendations.
▸ Designed risk-based policies, client risk classification methodologies, and EDD protocols tailored to each
business line — including enhanced source-of-funds/source-of-wealth frameworks for real estate and vault
clients (high-risk DNFBP segments).
▸ Owned the end-to-end KYC/CDD/EDD programme — sanctions and adverse media screening, UBO
identification, PEP controls, and periodic review across all business lines.
▸ Established the groups compliance monitoring programme, internal controls testing cycle, and audit and
inspection readiness protocols across multiple supervisory touchpoints.
▸ Delivered tailored AML training across all business lines, lifting compliance awareness among relationship
managers, brokers, vault operators, and advisory staff.

Compliance Officer at a multi-jurisdictional CMA/SCA Category 1 licensed commodities brokerage — covering client
onboarding, AML monitoring, trade surveillance, and regulatory reporting.
▸ Performed KYC/CDD and ongoing due diligence on brokerage clients — corporate structures, UBO
identification, sanctions and adverse media screening, and EDD on elevated-risk relationships.
▸ Reviewed client trading activity and setlement flows for AML red flags, unusual paterns, and potential market
abuse indicators, escalating concerns through internal compliance channels.
▸ Produced compliance reports, management information, and analytics supporting risk commitee oversight;
maintained inspection-ready compliance registers aligned to UAE regulatory expectations.
▸ Collaborated with global compliance counterparts to align policies, escalation protocols, and reporting
standards across the group.

▸ Reviewed electronic communications of financial advisors, bankers, and front-office staff to identify regulatory
breaches, conflicts of interest, misconduct, and reputational risk indicators.
▸ Acted as senior escalation point and subject mater expert for complex surveillance cases; contributed to
training and quality assurance across the surveillance function.

▸ Reviewed employee electronic communications to identify regulatory breaches, market abuse indicators, and
misconduct; contributed to lexicon refinement and alert scenario tuning.

▸ Conducted e-communications surveillance across emails, IMs, and chat using Global Relay, Compliance
Accelerator, and Bloomberg Vault to detect insider trading, market abuse, fraud, bribery, and AML-related
misconduct.

Frontline fraud and financial crime role covering client onboarding, trade monitoring, and account-level risk across
retail brokerage operations.
▸ Conducted end-to-end fraud investigations across account takeovers, identity theft, unauthorised trading,
wire fraud, and payment manipulation.
▸ Monitored retail trading activity for suspicious paterns — wash trades, pump-and-dump indicators, unusual
options activity, and market abuse red flags — escalating for further review.
▸ Owned KYC/CDD and client onboarding due diligence including identity verification, UBO checks, EDD on
elevated-risk profiles, and adverse media screening across retail brokerage accounts.
▸ Identified emerging fraud typologies and recommended control enhancements to the risk mitigation
operating model; supported training and development of junior analysts.