Regulatory Compliance

Independent audits
that satisfy regulators.

Independent AML/CFT audits and regulatory compliance reviews across the UAE — designed to find gaps before DFSA, FSRA, SCA, CBUAE or the Ministry of Economy do. Like an internal audit, but for compliance.

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When you need one

Many UAE regulators require an independent AML/CFT audit on a periodic basis — typically annually or biennially depending on the regime and the firm's risk profile. DFSA, FSRA and CBUAE all have specific expectations. DNFBPs under the Ministry of Economy have their own framework.

Even where not strictly mandated, a regular independent AML audit demonstrates good governance — and is often the difference between a clean regulator inspection and an enforcement action.

Scope of the audit

  • AML/CFT framework — governance, policies, procedures and risk assessment
  • Customer onboarding and CDD — sample testing of customer files against documented procedures
  • Risk classification — accuracy of risk-rating decisions
  • Enhanced due diligence — PEP identification, high-risk customer review
  • Transaction monitoring — rule design, alert disposition, false-positive analysis
  • Sanctions screening — list maintenance, screening cadence, alert handling
  • Suspicious activity reporting — escalation effectiveness, STR/SAR quality
  • Training — coverage, content quality and attendance records
  • Governance and reporting — committee oversight, board reporting, MLRO independence
Independent assurance

Why an independent
AML audit matters.

Most UAE regulators require an independent AML/CFT audit on a periodic basis — typically annually for higher-risk firms, biennially for others. DFSA AMLR Rule 14, FSRA AML Rulebook Chapter 11, CBUAE regulations and the Ministry of Economy DNFBP framework all have specific independent audit expectations.

Scope of an AML audit

The audit tests whether your AML/CFT controls are not just documented but actually working. Typical scope includes:

  • Sample testing of CDD files (initial and ongoing)
  • Sanctions screening effectiveness testing
  • Transaction monitoring rule validation
  • STR and SAR escalation testing
  • Training records and effectiveness
  • Governance — board oversight, MLRO independence, MI quality
  • Sample re-performance of CDD reviews

Regulatory compliance reviews — broader scope

A regulatory compliance review goes wider than just AML — it tests your overall compliance practices against your full regulatory rulebook (DFSA, FSRA, SCA, CBUAE or DNFBP), looking at how policies are implemented in reality. Think of it as an internal audit for compliance. The best time to find a compliance gap is before the regulator does.

Our process

How an AML audit
runs in practice.

Planning and risk-based scoping

Review your risk assessment, prior audit findings and regulator correspondence. Scope the audit based on inherent risk — sampling rate, testing depth, focus areas.

Document and policy review

Review the AML manual, CDD procedures, sanctions screening, transaction monitoring rules, training records and prior STR/SAR filings.

Sample testing

Statistical sample testing of CDD files, sanctions screening hits, transaction monitoring alerts and STR escalations. Walk-throughs of key controls with the team.

Reporting

Formal audit report with risk-rated findings, prioritised remediation recommendations and management action plan. Suitable for submission to the regulator if requested.

FAQ

Frequently asked.

How often do I need an independent AML/CFT audit?+
Most UAE regulators require an independent AML audit annually for higher-risk firms and biennially for lower-risk firms. DFSA AMLR Rule 14, FSRA AML Rulebook Chapter 11 and CBUAE regulations all have specific frequency expectations. Ministry of Economy DNFBPs follow the DNFBP framework requirements.
Can my external statutory auditor also do my AML audit?+
Generally no — for independence reasons. The same firm cannot usually act as both external auditor of the financial statements and internal AML auditor. We can do either, but not both, for a given client.
What is a regulatory compliance review?+
A regulatory compliance review tests your overall compliance practices against your full regulatory rulebook (DFSA, FSRA, SCA, CBUAE or DNFBP) — broader than just AML. It tests how policies are implemented in reality. Think of it as an internal audit for compliance.
What happens if the audit finds significant issues?+
Findings are reported in priority order with recommended remediation. We typically work with management to agree an action plan with deadlines and owners. For very serious findings, the firm may need to self-report to the regulator — we can advise on that decision.
Can the audit report be shared with the regulator?+
Yes — many UAE regulators expect to see the independent AML audit report on request, particularly during supervisory inspections or risk assessments. The report is typically issued in a format suitable for sharing with the regulator.
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