Do we need to hire a full-time compliance officer?

The question in full

Understand the Compliance Officer Requirement when operating under a sponsorship model and why startups may not need one initially.

Answer

Under a sponsorship model, you do not need a compliance officer (either part-time or full-time), as you are not taking custody of funds. The funds are essentially being ‘handled’ for you, on your behalf as per the agreed terms. So, strictly speaking, a compliance officer is NOT needed.

Whilst it certainly helps to have one (going forward when you expand your business and get your own licenses), to start out, you do not need one, as the onus of the transactions is not on you.

Do we need to hire a full-time compliance officer?

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