In short: Use a recruiter to find people, and an employer of record (EOR) to employ people in countries where you have no entity. For regulated key functions (compliance officer, MLRO/AMLCO, key individuals, licensed-entity directors), the person should normally be employed by the licensed entity itself, not by an EOR. Regulators approve individuals for a role at the licensed firm, and some rules forbid outsourcing those functions outright. EOR is a good fit for non-regulated roles such as sales, support, marketing and engineering in markets where you are not yet set up.
What each one actually does
| Recruiter (e.g. HRFinEase) | Employer of Record | |
|---|---|---|
| Finds and screens candidates | Yes | Usually no |
| Legal employer | You (the licensed entity) | The EOR provider |
| Runs payroll, tax, local contracts | No (we can refer this) | Yes |
| Typical pricing | One-off fee on placement | Monthly fee per employee for as long as they are employed |
| Fits regulated key functions | Yes | Generally no |
| Fits remote non-regulated hires abroad | Yes, as sourcing | Yes, as employment |
They solve different problems. Many fintechs use both: a recruiter to find a retention team in a new market, and an EOR to employ that team until a local entity exists.
Why regulated roles belong on the licensed entity's payroll
The approval is tied to the firm
When CySEC, the UAE's Capital Market Authority, the FSC Mauritius or the Seychelles FSA approves a compliance officer or MLRO, they are approving that person for that licensed firm. Since 1 January 2026, for example, board and executive appointments at CMA-licensed firms need prior Authority approval. An EOR in the middle blurs who the regulated person actually works for and answers to.
Some rules ban outsourcing the function
In Mauritius, the FIU's guidance on the FIAMLR 2018 states that the MLRO and Compliance Officer functions should sit at senior management level and may not be outsourced. In Seychelles, the AML/CFT Regulations 2020 require the compliance officer and an alternative compliance officer to be approved by the supervisory authority, and the alternate must be physically present in Seychelles when acting.
Personal liability needs a clear chain of command
An MLRO carries personal legal exposure for failing to report suspicions. They need direct access to your board, your data and your systems, plus the authority to escalate. That relationship works best when the MLRO is your employee.
Even EOR providers say this. Guidance published by one EOR firm for fintech clients concludes that MLROs, compliance heads and other approved persons should sit on the licensed entity's own payroll, not on EOR paper.
Where an EOR makes sense
- Market entry before licensing. For example, sales or business development staff in a new country while you decide whether to set up locally.
- Non-regulated remote roles. Developers, designers, marketing, customer support and many back-office roles.
- Small teams in many countries. Two retention agents in one market and three in another don't justify an entity each.
- Trial periods before relocation. You can employ someone remotely through an EOR, then move them onto the licensed entity once they relocate.
A simple decision rule
- Does the regulator approve, register or assess this person? If so, they go on the licensed entity's payroll. Use a recruiter to find them.
- Do you have an entity in the country where the person will live? If so, employ them directly. If not, and the role is non-regulated, an EOR is a sensible bridge.
- Will the role become regulated later? That applies to, for example, a dealer who will be certified, or an analyst who will become a key person. Hire them directly from day one to avoid moving them later.
This is a practical framework, not legal advice. Confirm role classification with your regulator and local counsel.
How HRFinEase fits in
We recruit for regulated roles across Cyprus, the UAE, South Africa, Mauritius, Seychelles, Labuan and Latvia. The fee is one month of gross salary, payable only once the candidate starts. For teams that also need payroll, contracts or cross-border employment, see our global payroll, payroll outsourcing and employment contracts services.
FAQ
Can an MLRO be employed through an employer of record? Generally not advisable. Regulators approve the MLRO for a specific licensed firm, and some jurisdictions, including Mauritius under the FIAMLR 2018, do not allow the function to be outsourced.
Is an EOR cheaper than a recruiter? They charge for different things. A recruiter charges once, on placement. An EOR charges a monthly fee for as long as the person is employed. Over a multi-year hire, the EOR usually costs more.
Can I use an EOR for customer support or sales in a new country? Yes. Non-regulated roles in countries where you have no entity are where an EOR is most useful.
Can HRFinEase find candidates who will then be employed through an EOR? Yes, for non-regulated roles. We source and screen, and you or your EOR provider employ the person.
Sources
- FIU Mauritius, Tip of the Month: The MLRO and the Compliance Officer (FIAMLR 2018, regs 22 and 26)
- Seychelles AML/CFT Regulations 2020, reg. 8: finance.gov.sc
- Al Tamimi & Co., UAE capital market regulatory overhaul: key changes from 1 January 2026
- Borderless AI, EOR for fintechs (2026)