What Is an Internal Audit?
Internal Audit is the conscience of an organisation, trained to speak in facts rather than feelings.
It is an independent and objective assurance function that examines whether governance, risk management, and internal controls operate as they are proclaimed to do. Internal Audit concerns itself less with declared intent and more with lived reality. It asks whether authority is exercised responsibly, whether risk is understood soberly, and whether controls endure beyond policy documents.
A coherent Internal Audit Framework provides the intellectual architecture for this work. It defines independence, reporting lines, scope, and accountability with deliberate clarity. The Internal Audit Process then animates this structure through disciplined planning, methodical testing, evidence-based reporting, and persistent follow-through. Each stage serves a single purpose: to replace assumption with assurance. Get in touch with us to avail GRC services in UAE.
Frameworks Written for UAE
Internal Audit in the UAE cannot be imported wholesale. It must be written, tested, and exercised on local soil.
The regulatory landscape here is sophisticated and multi-layered. Mainland entities operate under the oversight of the Central Bank of the UAE, alongside the Ministry of Economy and Tourism and the Ministry of Justice. In the financial free zones, expectations are shaped by regulators such as the ADGM FSRA and the DIFC DFSA, while digital asset firms must engage closely with VARA, the Securities and Commodities Authority, and newer ecosystems, including RAK DAO.
An Internal Audit Framework built for this environment must reflect the UAE AML Law and the practical application of Federal Decree Law No. 10 of 2025, with audit coverage aligned to the CB UAE AML CFT Rulebook and relevant ministerial guidance. Regulators expect Internal Audit to test controls.
Why are Internal Audits Important?
An Internal Audit framework is important because regulation rewards evidence and penalises assumptions.
In the UAE, regulators examine how controls function in practice, not how confidently they are described. Internal Audit provides independent assurance that governance, risk management, and internal controls are operating as intended. It allows boards and senior management to identify weaknesses early, when correction is still measured rather than mandated.
A well-defined Internal Audit Framework enables effective oversight.
- It gives the board an unfiltered view of operational and compliance risk.
- It confirms whether controls are properly designed and consistently applied.
- It tests whether risk appetite is observed across functions, not only approved on paper.
A disciplined Internal Audit Process strengthens regulatory readiness.
- It identifies control gaps before inspections and supervisory reviews.
- It tests compliance with UAE AML Compliance obligations under Federal Decree Law No. 10 of 2025 and the CB UAE AML CFT Rulebook.
- It ensures findings are remediated, documented, and formally closed.
In higher-risk environments, its role is critical.
- It tests AML controls and transaction monitoring with independence.
- It reviews AML Compliance for VASPs against FATF Virtual Asset Guidance.
- It assesses governance and control risks in technology-led and fast-scaling businesses.
From GRC Advisors’ perspective, the Internal Audit framework provides order where complexity grows. It anchors governance, disciplines risk-taking, and enables organisations to operate with regulatory confidence in the UAE’s exacting supervisory environment. Get in touch with us to avail GRC Services in UAE.
Protect board members and senior management from personal and regulatory exposure
Reduce friction during inspections, supervisory reviews, and regulatory engagement
Support faster licensing decisions and smoother approval processes
Build confidence with banks, counterparties, investors, and strategic partners
Introduce decision-making discipline as organisations grow in scale and complexity
Put simply, governance is what keeps an organisation steady as expectations rise and scrutiny intensifies. It keeps the wheels on when the road becomes uneven.
Our Internal Audit Services
Internal Audit Setup
Internal Audit Setup establishes the authority and discipline of the function from the outset. It ensures Internal Audit is independent, structured, and aligned with both regulatory expectations and organisational reality.
What we do
- Establish a formal Internal Audit Charter with clear mandate and reporting lines
- Design an Internal Audit Framework aligned to regulatory and board requirements
- Develop a consistent audit methodology suitable for regulatory scrutiny
- Define the audit universe based on risk, regulation, and business activities
- Implement an operating model covering escalation, interaction, and reporting
Audit Planning
Audit Planning determines whether Internal Audit focuses on real risk or procedural comfort. A disciplined plan ensures audit effort is directed where failure would matter most.
What we do
- Develop a risk-based annual audit plan grounded in business and regulatory risk
- Integrate AML, compliance, governance, and operational risk into planning
- Define audit scope, depth, and frequency with proportionality
- Assess resourcing needs and delivery timelines
- Prepare audit committee and board approval packs
Thematic Audits
Thematic Audits provide focused assurance in areas of heightened or emerging risk. They allow boards to understand systemic issues that cut across functions and processes.
What we do
- Conduct targeted reviews across governance, compliance, and control effectiveness
- Perform thematic audits on AML controls, technology risk, outsourcing, and resilience
- Examine cross-functional risk rather than isolated activities
- Identify recurring weaknesses and control gaps
- Deliver clear findings with prioritised recommendations
Audit Issue Closure
Audit Issue Closure ensures that findings are resolved properly, not forgotten. It provides assurance that remediation actions are effective and sustained.
What we do
- Track management actions against agreed timelines
- Review and validate closure evidence objectively
- Challenge superficial or incomplete remediation
- Report closure status to senior management and the board
- Confirm formal issue closure once effectiveness is demonstrated
Audit Quality Review
Audit Quality Reviews assess whether Internal Audit itself meets professional and regulatory expectations. They provide clarity on strengths, gaps, and areas requiring improvement.
What we do
- Assess Internal Audit against recognised standards and regulatory expectations
- Review planning, execution, reporting, and issue management quality
- Evaluate independence, capability, and consistency
- Identify gaps between current practice and expected maturity
- Deliver a structured improvement roadmap
Shall We Examine This Properly
Before Explanations Grow Elaborate and Meetings Grow Longer, a Composed Review Can Restore Order
Industries We Serve
Accountants and Auditors
Asset Managers & Investment Firms
DPMS
Insurance
Lawyers
Payments and Fintech
Real Estate
Securities & Brokerage
TCSPs
VASPs
The Fault Lines
Regulation is unforgiving of improvisation.
Across the UAE, firms rarely fall short because they ignore the rules. They falter because governance that reads well does not always perform well. Internal Audit is where this difference becomes visible. It is the point at which intention is tested, execution is examined, and explanations give way to evidence.
The pain points below are not theoretical. They are drawn from regulatory reviews, supervisory meetings, and audit committees where the same questions recur insistently. They reflect how different regulators apply scrutiny in practice, and where firms most often struggle to respond with confidence.
What follows is not a catalogue of failures, but a map of familiar pressure points, organised by regulatory environment.
VASPs
Many VASPs build governance to be approved, not to be lived with.
- Frameworks are assembled to secure VARA licensing, then left largely unchanged.
- Compliance monitoring and transaction oversight remain shallow once operations scale.
- Escalation mechanisms exist, but hesitate at the moment they are needed most.
- Internal Audit finds it difficult to demonstrate AML Compliance for VASPs when tested against FATF Virtual Asset Guidance.
The result is familiar. The licence is granted, but supervision exposes gaps across technology, custody, market conduct, and AML that were never stress-tested.
DIFC Firms
DIFC firms are rarely under-governed. They are often over-structured.
- Multiple committees exist, yet accountability disperses rather than concentrates.
- Mandates are inherited from earlier phases of growth and never recalibrated.
- Reporting lines fracture the audit narrative into parts that do not quite speak to each other.
During inspections by the DIFC DFSA, Internal Audit reports are defensible individually, but struggle to explain how governance works as a whole.
ADGM Entities
In ADGM, the problem is seldom intent. It is proof.
- Policies are clear, current, and well understood.
- Execution varies quietly across teams and functions.
- Oversight exists, but evidence of challenge and follow-through is thin.
When reviewed by the ADGM FSRA, Internal Audit confirms that frameworks are designed well, yet cannot always show that they are exercised consistently.
SCA-Regulated Firms
Here, pressure accumulates gradually and reveals itself late.
- Compliance teams are stretched by transaction volume and regulatory change.
- Monitoring is uneven across products and channels.
- Breaches are addressed, but escalation often arrives after patterns have formed.
Internal Audit encounters repeat findings, not because controls are unknown, but because capacity and structure have not kept pace with regulatory expectation under the Securities and Commodities Authority.
Mainland and Free Zone Companies
Governance often arrives only when demanded.
- Internal Audit is introduced reactively, prompted by banks or regulators.
- Roles and accountability remain loosely defined.
- Issue remediation lacks discipline and formal tracking.
Scrutiny from the Central Bank of the UAE, the Ministry of Economy and Tourism, or the Ministry of Justice tends to surface these weaknesses abruptly.
Why GRC Advisors for Internal Audit
GRC Advisors approaches Internal Audit from the vantage point of those who have sat through regulatory reviews, defended audit positions, and watched weak explanations unravel under polite questioning. Our credibility is built on exposure.
We are recognised in the UAE market for our work in AML, regulatory compliance, and governance advisory. That experience shapes how we deliver Internal Audit. We understand how regulators think, where they probe, and what they consider convincing. This perspective informs every audit plan, every finding, and every closure decision.
What distinguishes our approach is relevance.
- We design Internal Audit Frameworks that align with supervisory expectations under the Central Bank of the UAE, ADGM FSRA, and DIFC DFSA.
- We integrate AML risk, regulatory change, and governance oversight into audit coverage, rather than treating them as separate disciplines.
- We bring deep experience from AML Consultancy and AML Consulting engagements, where deficiencies are examined without sympathy and remediation must be exact.
Clients work with GRC Advisors because we understand the difference between passing an audit and surviving supervision. Internal Audit, when delivered with experience and restraint, does both.
Appearance Are Charming, Evidence is Essential
A Measured Review Today Is Far Preferable to an Impromptu Defence Tomorrow