AML Policies and Procedures Services in UAE
AML policies and procedures are not a document you keep in a folder for comfort. These are written proof of how your institution survives scrutiny.
Under the UAE AML Law, together with Federal Decree Law No. 10 of 2025 and Cabinet Resolution No. 134 of 2025, every regulated entity in the United Arab Emirates is required to implement a risk-based AML and CFT framework. This requirement is not symbolic. It is enforceable, inspectable, and increasingly tested.
AML Policies and Procedures translate statutory language into operational discipline. They define how customers are risk-rated, how enhanced due diligence is triggered, how suspicious activity is escalated, how sanctions screening is conducted, and how governance oversight is exercised by the board and senior management.
This is particularly critical for firms operating under VARA licensing, the SCA virtual asset framework, or the ADGM FSRA Virtual Asset Framework. The regulatory landscape for digital assets is shaped by the VARA Rulebooks, the FSRA Virtual Asset Framework, the DFSA Crypto Token Regime, and the DIFC Digital Assets Law. These are informed by the FATF Virtual Asset Guidance and IOSCO Crypto Asset Principles, which demand more than surface-level compliance.
In practice, this means:
- A VASP mustdemonstrateAML Compliance for VASPs that integrate blockchain analytics and wallet governance.
- A firm in RAK DAO cannot assume that global templates satisfy local expectations.
- A regulated entity under the CB UAE AML CFT Rulebook must align its procedures with supervisory testing standards.
- DNFBPs supervised under MOECT Guidelines or MOJ Guidelines must ensure that their risk assessments are not generic or recycled.
Write AML Policies and Procedures That Endure
Partner with a GRC Consultancy Experienced in AML Compliance across the UAE
The Discipline of Regulators in UAE
AML Policies and Procedures in the United Arab Emirates are governed by a layered regulatory framework comprising federal legislation, cabinet resolutions, supervisory rulebooks, and sector-specific guidance.
At the federal level, the primary obligations arise under the UAE AML Law, read together with Federal Decree Law No. 10 of 2025 and Cabinet Resolution No. 134 of 2025. These instruments require all Financial Institutions and Designated Non-Financial Businesses and Professions to establish and maintain a risk-based AML and CFT framework.
At a minimum, regulated entities must:
• Conduct and document a formal enterprise-wide risk assessment
• Implement written AML/CFT policies, controls, and procedures proportionate to identified risks
• Apply customer due diligence and enhanced due diligence where required
• Monitor transactions on an ongoing basis
• Report suspicious transactions to the Financial Intelligence Unit
• Maintain records in accordance with statutory retention requirements
• Appoint a competent and independent MLRO
• Ensure board and senior management oversight
• Provide periodic AML training to staff
These obligations are supplemented by supervisory rulebooks depending on the licensing authority.
The Subtle Fault Lines
Common fault lines in AML policies and procedures include:
- Risk assessments are completed annually, but not reflected in updated AML Policies and Procedures under the UAE AML Law
- VARA licensing applications referencing blockchain analytics without operational evidence of monitoring controls
- AML Compliance for VASPs drafted without alignment to the VARA Rulebooks or FATF Virtual Asset Guidance
- Policies referencing the SCA virtual asset framework but failing to integrate market abuse risk
- Documentation citing the FSRA Virtual Asset Framework without calibrating transaction monitoring thresholds
- DIFC entities referencing the DFSA Crypto Token Regime while board oversight remains passive
- Governance minutes reflecting approval but not challenge
- MLRO appointments without demonstrable independence
Preparing for an Examination?
Strengthen Your AML Policies and Procedures with GRC Advisors Aligned to UAE Regulatory Expectation
The Construction of AML Policies and Procedures
A credible AML framework begins not with drafting, but with deliberate examination.
We Begin With Your Regulatory Perimeter
Before we write, we identify who will scrutinise you.
Whether you fall under VARA licensing, the SCA virtual asset framework, the ADGM FSRA Virtual Asset Framework, the DIFC DFSA Crypto Token Regime, or the Central Bank of the UAE, your AML Policies and Procedures must reflect the expectations of that authority.
We map your obligations under:
- UAE AML Law
- Federal Decree Law No. 10 of 2025
- Cabinet Resolution No. 134 of 2025
- VARA Rulebooks
- FSRA Virtual Asset Framework
- DFSA Crypto Token Regime
- CB UAE AML CFT Rulebook
- MOECT Guidelines
- MOJ Guidelines
AML Consulting without regulatory mapping produces documents.
GRC Advisory produces defensible frameworks.
We Challenge the Risk Assessment
Every AML framework must be built on a genuine enterprise-wide risk assessment.
We analyse:
- Products and service lines
- Client types and onboarding channels
- Geographic exposure
- Delivery mechanisms
- Technology infrastructure
For GRC for VASPs, this includes blockchain analytics oversight, wallet governance, token issuance exposure, and cross-border transaction risk in line with FATF Virtual Asset Guidance and IOSCO Crypto Asset Principles.
If the risk assessment does not influence monitoring thresholds, due diligence standards, and escalation procedures, it is incomplete.
We do not allow decorative risk assessments.
We Structure Governance Before Drafting Policy
Regulators across VARA, SCA, ADGM FSRA, DIFC DFSA, and the Central Bank of the UAE expect visible accountability.
We establish:
- Clear MLRO authority and independence
- Defined escalation pathways
- Board reporting mechanisms
- Documented oversight responsibilities
A policy cannot compensate for weak governance.
It can only expose it.
We Draft Policies That Reflect Operations
This is where many firms falter.
Policies often describe ideal processes. We draft procedures that mirror actual operations and can withstand regulatory questioning.
Your AML Policies and Procedures will address:
- Customer due diligence and enhanced due diligence triggers
- Sanctions screening controls
- Transaction monitoring logic and calibration
- Suspicious Activity Report escalation
- Record retention standards
- Training and independent review cycles
For AML Compliance for VASPs, we integrate blockchain analytics, Travel Rule requirements, custody governance, and technology risk controls aligned with the ADGM FSRA Virtual Asset Framework and VARA Rulebooks
We Test Control Logic
Under the CB UAE AML CFT Rulebook and supervisory practices across the UAE, regulators expect documented rationale.
We test:
- Monitoringthresholds
- Risk scoring methodology
- EDD consistency
- Documentation discipline
- Governance reporting quality
If a control cannot be explained clearly, it will not survive examination.
We Support Implementation and Readiness
UAE AML Compliance does not end with board approval.
We ensure:
- Staff understand procedural triggers
- Monitoring systems align with policy language
- Escalation is documented
- Periodic review cycles are embedded
This is where disciplined GRC Consultancy makes the difference. Policies must be operational, measurable, and aligned with supervisory reality.
An Advisory for Those Who Prefer Certainty
Regulation in the United Arab Emirates rewards preparation, maturity, and quiet precision. AML frameworks are examined with care, and they reveal far more about an institution than a licence certificate ever will. The advisor you choose shapes how confidently that scrutiny is met.
Here, then, is why GRC Advisors merits the responsibility.
- A cultivated understanding of the UAE regulatory climate informs every framework we design.
- Years spent navigating supervisory dialogue shape the way each AML structure is articulated.
- Careful drafting ensures that policy language carries both legal weight and operational meaning.
- Expectations across VARA, SCA, ADGM FSRA, DIFC DFSA, and the Central Bank of the UAE are interpreted with nuance and regulatory awareness.
When Regulation Looks Closer
Ensure Your AML Policies and Procedures Reflect Preparation, Proportion, and Awareness