A working AML
programme, built right.

What a real AML programme looks like

An AML/CFT programme isn't a policy document on a shelf. It's a working set of controls — risk assessment, customer due diligence, transaction monitoring, sanctions screening, suspicious activity reporting, training and governance — that actually function in your business, every day.

We build, refresh and operate AML programmes for regulated firms in the UAE.

What we cover

• Enterprise-wide AML risk assessment — annual, updated for new products, customers and geographies
• AML/CFT policies and procedures — written, reviewed and maintained current
• Customer due diligence framework — standard, simplified and enhanced CDD procedures
• Transaction monitoring rules — design, calibration and ongoing optimisation
• Sanctions screening setup — pre-transaction and ongoing screening, list maintenance
• Suspicious activity escalation — internal escalation protocols and STR/SAR workflows
• Training — onboarding training plus annual refresher for all relevant staff
• Governance — committee structure, reporting lines and oversight responsibilities
• Independent testing — annual independent review of programme effectiveness

Build vs refresh

For new firms we build the full programme from scratch as part of authorisation. For existing firms we typically come in for a refresh — gap analysis against current regulator expectations, remediation roadmap and updated documentation.