Questions to ask before hiring a compliance consultant

A consultant should sharpen your facts

Good compliance consultants do not merely fill forms. They challenge whether the business model, people, permissions, financial resources, and policies fit together. They make the application more regulator-readable without pretending to guarantee approval.

Before hiring anyone, prepare your own activity map. If you cannot explain the services, clients, products, asset flow, and people, you are not ready to judge whether the consultant's advice is practical.

Ask about comparable work, not generic expertise

A consultant who knows retail investment advice may not be the right person for a private fund manager. A crypto or fintech specialist may not be best for a traditional brokerage. Ask for relevant experience by jurisdiction, activity, client type, and regulator process.

Also ask how they monitor official-source changes. A consultant relying on old templates without checking SFC, MAS, FCA, SEC, FINRA, or ASIC updates can create avoidable risk.

Clarify what they will and will not do

Some consultants draft application packs. Some run mock interviews. Some build compliance manuals. Some provide ongoing monitoring. Some are not law firms and cannot provide legal advice. The scope should say who owns legal advice, regulatory interpretation, document drafting, submission, follow-up, and post-approval implementation.

If the consultant promises guaranteed approval, a structure that avoids regulation, or a shortcut that sounds too clean, treat that as a warning sign.

Demand a source-led work product

A useful deliverable should cite official regulator pages, explain assumptions, list open questions, and distinguish legal conclusions from operational recommendations. It should also include a correction process if an official source changes during the project.

LicenseCompare's methodology is built around this same principle: summarize carefully, link to official sources, and make limitations visible.

Ask for an issue map before a form pack

A strong consultant should be willing to produce an issue map before drafting a full application. The map should list the activities, likely permissions, people gaps, source links, evidence needed, assumptions, and open legal questions. It should also say what the consultant is not qualified to answer.

This protects the founder from buying a form pack too early. If the issue map shows unresolved broker-dealer risk, responsible officer gaps, SM&CR uncertainty, AFSL responsible manager weaknesses, or MAS client-classification problems, drafting forms is not the next best spend.

Check how they handle official-source changes

Ask the consultant what happens if regulator guidance changes during the project. Do they rerun source checks before submission? Do they maintain a source list? Do they distinguish official materials from market practice? Do they tell you when an answer is uncertain?

The answer matters because licensing projects can last months. A consultant who cannot show current source alignment may still be experienced, but the applicant should not rely on old templates alone. Source-led review is especially important for fast-moving areas such as platforms, digital assets, senior accountability, and cross-border marketing.

Define post-approval work up front

The application is only the start of the regulatory lifecycle. Ask whether the consultant will help with post-approval implementation: compliance calendar, register checks, staff training, policy rollout, reporting, complaints, financial crime monitoring, outsourcing reviews, and changes in control or variation planning.

Some consultants are excellent at applications but do not provide ongoing support. That can be fine if the firm knows it. The risk is assuming the application manual automatically becomes an operating compliance program without assigning owners, dates, systems, and review cycles.

How to compare proposals

Compare proposals by deliverable, not just price. One proposal may include route analysis, application drafting, policy customization, key person review, mock interviews, regulator response support, and post-approval implementation. Another may include only form completion. Those are different products.

Ask each consultant to identify what they need from you before work begins. A serious consultant will ask for entity information, ownership, client type, activities, product scope, people evidence, financial forecasts, outsourcing, custody, and marketing materials. If they need almost nothing, they may be selling a template rather than a tailored application.

Finally, ask how disagreements are handled. If counsel, consultant, and management disagree on a licensing question, who makes the final call, what source is checked, and how is the decision documented?