Sphere Private delivers independent compliance and regulatory expertise across Dubai, Geneva, Hong Kong, London, and Singapore. Led by General Counsel Salah Mattoo, our AML, anti-bribery, sanctions, and governance advisory ensures every wealth structure is legally sound, regulatorily robust, and reputationally secure for ultra-high-net-worth clients.
Independent. Rigorous. Multi-Jurisdictional.
For ultra-high-net-worth individuals, family offices, and corporates managing significant wealth across borders, compliance is no longer a back-office function. It is a frontline strategic discipline — one that protects assets, preserves reputation, and ensures that every structure, policy, and transaction can withstand scrutiny from regulators, banks, and counterparties across the world’s most demanding financial centers.
At Sphere Private, compliance and regulatory expertise sit at the core of every client engagement. Led by Salah Mattoo, General Counsel, Head of Compliance and Operations, our advisory integrates deep legal, regulatory, and governance knowledge into the design and placement of every bespoke life insurance and wealth planning solution we deliver — across Dubai, Geneva, Hong Kong, London, and Singapore.
The global regulatory landscape has transformed fundamentally over the past decade. Transparency initiatives including FATCA, the OECD Common Reporting Standard (CRS), and successive waves of AML reform have closed the gaps that once allowed undisclosed or loosely structured offshore arrangements to persist without consequence.
Today, the consequences of non-compliance extend far beyond financial penalties. For UHNW individuals and families, regulatory failures can freeze assets, trigger criminal liability, damage banking relationships, and destroy reputations that have taken generations to build.
The UAE’s own journey reflects this shift. Following its removal from the FATF grey list in February 2024 and its removal from the EU’s list of high-risk third countries for AML purposes in August 2025, the UAE has introduced a significant new federal AML law that extends personal liability to managers, lowers the knowledge threshold for offences, and broadens the AML framework to cover virtual asset service providers — all with clear enforcement intent extending into 2026 and beyond.
The DFSA’s authorised firm count grew by 14% year-on-year during 2024, with more than 900 firms now under its jurisdiction and a 75% increase in wealth management licences — creating a more competitive but also far more closely supervised environment.
Against this backdrop, independent, expert compliance advisory is not a luxury. It is a prerequisite for confident, sustainable wealth management.
Meet Salah Mattoo: General Counsel, Head of Compliance and Operations
Sphere Private’s compliance and regulatory framework is anchored by Salah Mattoo, who serves as General Counsel, Head of Compliance and Operations.
Salah brings deep, multi-jurisdictional expertise across the following critical disciplines:
Salah’s role ensures that compliance is not a constraint imposed on Sphere Private’s advisory — it is a foundational pillar that makes every structure we deliver more robust, more credible, and more durable.
A Multi-Jurisdictional Compliance Framework Built for UHNW Clients
UHNW individuals and families present uniquely complex compliance profiles. Their asset structures span multiple jurisdictions, their ownership chains often include trusts, foundations, and corporate layers, and a significant proportion hold PEP status or have family members who do.
Global regulators — from FinCEN to Singapore’s MAS — now mandate enhanced due diligence, comprehensive source-of-wealth verification, and continuous monitoring for this client segment. Institutions that fail these standards face severe consequences, from multi-million-dollar fines to license revocation and forced closure. Singapore’s permanent shutdown of BSI Bank and Falcon Private Bank following 1MDB-related AML failures stands as the most prominent recent example of how seriously regulators treat compliance failures at the UHNW level.
At Sphere Private, our compliance framework addresses the full spectrum of these challenges across all five of our primary operating markets:
The UAE’s AML environment has undergone its most significant transformation in a generation. Sphere Private’s compliance approach in Dubai is aligned with the new federal AML law, DFSA requirements, and DIFC-specific data protection and governance standards. For clients based in Dubai, this means:
Switzerland’s financial services sector operates under one of the most rigorous compliance regimes in the world. Sphere Private’s Geneva-related engagements reflect the high standards expected by FINMA and Swiss anti-money laundering legislation, particularly for cross-border estate planning involving European tax residents. Key considerations include:
Hong Kong remains one of Asia’s most sophisticated and closely regulated financial centers. Sphere Private’s compliance approach for Hong Kong-connected clients addresses:
The UK’s compliance environment continues to evolve rapidly. Since September 2023, the failure-to-prevent fraud offence has exposed private banks and wealth management firms to criminal liability for the conduct of associated persons — a development that has substantially raised the bar for governance and oversight in client-facing advisory.
For London-connected clients, Sphere Private ensures:
Singapore’s MAS has demonstrated some of the most rigorous enforcement of AML and governance standards globally, particularly following the 1MDB scandal, which resulted in the permanent closure of two international private banks. Singapore’s involvement in FATCA and CRS also makes meticulous reporting a non-negotiable baseline for any family office or wealth structure based there.
For Singapore-connected clients, Sphere Private’s compliance approach covers:
At Sphere Private, compliance is not reviewed at the end of a transaction. It is integrated from the very first client conversation.
Our advisory process is structured to ensure that every recommendation — whether for a high-value life insurance placement, premium financing structure, family office insurance strategy, or estate planning arrangement — has been assessed for:
1. Regulatory Permissibility
Every product, carrier, and structure is reviewed for licensing compliance across all relevant jurisdictions. We do not recommend solutions that are impermissible in the client’s country of residence, domicile, or where their key assets are held.
2. Source-of-Wealth and KYC Standards
Consistent with the standards expected by leading international carriers, regulators, and banks, Sphere Private applies rigorous KYC and source-of-wealth procedures to all client relationships. This protects clients as well as the integrity of the advisory relationship.
3. Sanctions and PEP Screening
All prospective clients and connected parties are screened against applicable sanctions lists and assessed for PEP status prior to engagement. Where enhanced due diligence is required, it is conducted thoroughly and documented clearly.
4. Anti-Bribery and Conduct Standards
Our advisory processes are designed to eliminate any possibility of bribery, improper inducement, or conduct that could create liability under applicable anti-corruption legislation. All intermediary relationships are subject to appropriate due diligence and contractual conduct standards.
5. Governance Documentation
Every structure Sphere Private advises on is supported by clear, legally coherent documentation — including trust deeds, foundation by-laws, policy ownership structures, and beneficiary frameworks — that reflects the client’s genuine intentions and can withstand regulatory or legal scrutiny in any relevant jurisdiction.
There is a direct and important relationship between compliance quality and advisory outcomes at the UHNW level.
A life insurance structure that is not compliant with the client’s home-country tax rules may generate an unexpected liability. A family office foundation without proper beneficial ownership documentation may fail bank due diligence reviews and freeze access to capital. A premium financing arrangement placed through an unlicensed intermediary may be challenged and unwound. An offshore insurance policy placed without proper CRS disclosure may attract regulatory attention at the worst possible moment.
Every one of these risks is avoidable with the right compliance expertise in place from the outset.
Sphere Private’s independence means that we are not constrained by the product or geography limitations of a single carrier or institution. Our compliance framework, led by Salah Mattoo, ensures that this independence is exercised within the highest standards of regulatory integrity — so that the structures we design are not only technically sophisticated and commercially optimal but also durable, defensible, and fully aligned with our clients’ long-term interests.
For ultra-high-net-worth families and business owners, the consequences of compliance failure are not only financial. Regulatory investigations, asset freezes, and AML-related scrutiny can damage commercial relationships, family reputations, and long-term business viability in ways that are far more costly than any penalty.
Sphere Private’s compliance-first approach is therefore as much a reputational service as a legal one. Clients who engage Sphere Private can be confident that every structure, placement, and advisory recommendation has been designed not only to meet their planning objectives but also to protect the integrity and standing they have built over a lifetime.
Discretion is not simply a feature of our service — it is a structural commitment, embedded in how we handle data, manage documentation, communicate with carriers and intermediaries, and design client engagements from start to finish.
Whether you are a UHNW individual structuring your estate across Dubai and London, a family office principal coordinating assets between Geneva and Singapore, or a corporate group managing cross-border succession in Hong Kong, Sphere Private’s compliance expertise ensures that your wealth plan is built on foundations that are legally sound, regulatorily robust, and reputationally secure.
Our 20+ years of experience, 500+ clients served, and 500+ cross-border transactions have all been conducted within the highest compliance standards — because at the level of wealth and complexity our clients operate at, there is simply no other acceptable approach.
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Serving clients in Dubai · Geneva · Hong Kong · London · Singapore
Salah Mattoo is an experienced international lawyer and accomplished executive, currently serving as General Counsel and Head of Compliance. He specialises in dispute resolution, corporate and commercial transactions, regulatory compliance, and internal and external investigations across multiple jurisdictions.
Salah has acted in a range of high-profile international arbitration and cross-border litigation matters, representing corporate clients, sovereigns, and institutions in complex, high-stakes disputes. Salah's background includes advisory and leadership roles in sectors such as insurance, private equity, financial services, defence, commodities, energy, technology, and infrastructure.
In addition to his disputes practice, Salah has led the design and implementation of robust compliance programs aligned with international best practices, including AML, anti-bribery, sanctions, data privacy, ESG, and whistleblower frameworks. Salah regularly advises executive teams and boards on legal risk management, governance structures, and regulatory strategy.
With a strong track record in both contentious and transactional matters, Salah combines legal precision with strategic insight to support businesses navigating regulatory complexity and international growth. Salah is qualified in England & Wales, DIFC and ADGM. He has acted as lead counsel in international commercial courts, as well as in many international arbitrations seated in the leading arbitration centers, including Abu Dhabi, Dubai, Geneva, Hong Kong, London, New York, Paris, Riyadh, Singapore, Stockholm, Tokyo, Vienna, Washington and Zurich.
Salah holds a B.A. from University of California, Berkeley and an L.L.B and L.L.M. from The London School of Economics and Political Science (University of London).
Dubai · Geneva · Hong Kong · London · Singapore
Imran Khan is a seasoned expert in private wealth planning and jumbo life insurance solutions, with over 10 years of experience advising ultra high net worth individuals (UHNWIs), families, and family offices across multiple jurisdictions. With a deep understanding of global wealth structuring, legacy planning, and asset protection, Imran is recognized for delivering highly customized strategies that align with clients personal, business, and multigenerational goals.
Throughout his career, Imran has worked closely with private banks, trust companies, and legal advisors to design and implement sophisticated structures involving international trusts, foundations, holding companies, and life insurance-based estate equalization plans. His expertise includes:
Imran holds specialist accreditations in wealth planning and international insurance advisory and is a trusted advisor to clients across the Asia, Europe, Middle East and UK. Known for discretion, technical proficiency, and strategic insight, he has built enduring relationships with UHNW families seeking to preserve and grow their legacies in an increasingly complex regulatory environment.
Dubai · Geneva · Hong Kong · London · Singapore