Ensuring Compliance with Article (6): The Fit and Proper Process

As a Partner at Baker Tilly, I have witnessed firsthand how regulatory compliance is shaping the future of banking in the UAE and across the region. One of the most critical requirements under the Central Bank of the UAE (CBUAE) Corporate Governance Regulations is Article (6): The Fit and Proper Process. This regulation is not just a checkbox, it is a cornerstone of trust, integrity, and sound governance in financial institutions.

Why Article (6) Matters?

Article (6) mandates that banks and financial institutions conduct a thorough assessment of individuals in key roles, those who influence risk, governance, and decision-making. The process ensures that these individuals meet the highest standards of:

• Integrity and honesty
• Professional competence and experience
• Financial soundness
• Regulatory compliance history

This is essential for maintaining confidence in the financial system and protecting stakeholders.

Implementation Deadline

The CBUAE Fitness and Propriety Regulation (Circular No. 4/2024) became effective on 31 October 2024.

Banks must complete the Fit and Proper Process within nine (9) months of this date, meaning the deadline was 31 July 2025.

This includes:

• Assessing all individuals in Designated Functions who have not been previously authorized.
• Reviewing Material Risk Takers whose assessment has not been conducted within the last three years.
• Submitting a report of the exercise to the Central Bank.

Failing to meet this timeline can result in regulatory non-compliance and reputational risk.

Our Role in Supporting Banks

At Baker Tilly, we are proud to assist numerous banks across the region in implementing robust Fit and Proper processes. Our specialized Employee Background Verification Services are designed to align with CBUAE’s regulatory expectations and include:

• Reference Verification – Confirming professional reputation and ethical conduct through direct engagement with previous employers and referees.
• Education & Employment Checks – Validating academic qualifications and career history.
• Regulatory Screening – Reviewing any past disciplinary actions or compliance breaches.
• Global Sanctions & Adverse Media Checks – Identifying potential reputational or compliance risks.

Adding Value Beyond Compliance

At Baker Tilly, our focus is not only on helping banks meet regulatory requirements but also on creating a culture of trust and transparency. A well-executed Fit and Proper process:

• Reduces operational and reputational risk
• Strengthens governance frameworks
• Enhances stakeholder confidence
• Supports sustainable growth in a competitive market

Our approach goes beyond ticking boxes, we deliver insights that help institutions make informed decisions about leadership and risk-sensitive roles.

Why Choose Baker Tilly?

• Regional Expertise – Deep understanding of UAE Central Bank regulations and global best practices.
• Tailored Solutions – Customized verification processes for your organizational needs.
• Confidentiality & Accuracy – Ensuring sensitive data is handled with the highest standards of security.

Partner with Us

Compliance with Article (6): The Fit and Proper Process is a regulatory obligation and a strategic advantage. By partnering with Baker Tilly, you can confidently meet these requirements while reinforcing your institution’s commitment to integrity and excellence.

Let’s work together to build a stronger, more transparent banking ecosystem.