Independent assessment of your Anti-Money Laundering framework to ensure it remains effective, up-to-date, and aligned with UAE regulatory requirements.
What is an Annual AML Review?
An Annual AML Review (AML Audit) is an independent assessment of your Anti-Money Laundering framework to ensure it remains effective, up-to-date, and aligned with UAE regulatory requirements.
Regulators in the UAE expect all Financial Institutions and DNFBPs to periodically review their AML framework, covering policies, procedures, risk assessments, and operational controls.
This is not a formality — it is a critical exercise to ensure your compliance framework is working in practice, not just on paper.
Is AML Audit Mandatory in the UAE?
Yes — conducting periodic AML reviews is a regulatory expectation under UAE AML laws. All regulated entities must ensure that their AML framework is:
- Regularly reviewed and updated
- Aligned with current regulations
- Effective in identifying and mitigating risks
Failure to conduct an AML audit can result in regulatory penalties, inspection findings, and increased scrutiny.
Scope of Annual AML Review
Our AML Audit is a comprehensive, risk-based assessment covering:
- AML Policies & Procedures
- Business Risk Assessment (BRA)
- Customer Risk Assessment (CRA)
- Customer Due Diligence (CDD/EDD) processes
- Transaction monitoring systems
- Suspicious Transaction Reporting (STR) processes
- Sanctions screening and controls
- Record-keeping practices
- Governance and MLRO effectiveness
Integration with goAML & EOCN
An effective AML audit must assess alignment with key regulatory systems:
- goAML Reporting: Review your suspicious transaction identification and reporting process
- EOCN Compliance: Evaluate sanctions controls and alignment with export control requirements
We ensure your AML framework is fully integrated across all compliance obligations.
Common Issues Identified During AML Audits
- Outdated or generic AML policies
- Weak or undocumented procedures
- Incomplete or inaccurate risk assessments
- Gaps in CDD/EDD implementation
- Ineffective transaction monitoring
- Delays or errors in goAML reporting
- Lack of sanctions screening or EOCN alignment
- Poor documentation and record-keeping
How Often Should AML Audit Be Conducted?
AML reviews should be conducted at least annually, or more frequently if:
- There are regulatory changes
- Your business activities expand or change
- New products or services are introduced
- There is increased risk exposure
Who Needs an AML Audit?
- Financial Institutions
- DNFBPs (Real Estate, Precious Metals, Corporate Services, etc.)
- Businesses registered on goAML
- Entities subject to EOCN compliance
- Companies operating in high-risk or cross-border environments
