What Is AML/CFT Compliance?
AML and CFT compliance is the discipline of understanding financial crime risk before it crystallises into regulatory exposure. It requires firms to identify who they are dealing with, how funds move through their business, and whether transactions, customers, or structures create exposure to money laundering, terrorist financing, or proliferation financing. In the UAE, this obligation is anchored in the UAE AML Law, Federal Decree Law No. 10 of 2025, and Cabinet Resolution No. 134 of 2025, and reinforced through sector-specific rulebooks issued by the Central Bank of the UAE, VARA, SCA, ADGM FSRA, and DIFC DFSA. Effective AML compliance is risk-based, evidence-driven, and capable of standing up to supervisory review.
Effective AML compliance in this context is risk-based, evidence-driven, and demonstrably alive. Risk assessments must be documented, current, and defensible. Customer due diligence must show depth where risk is higher, especially for PEPs, complex ownership structures, and cross-border activity. Transaction monitoring and sanctions screening must be calibrated, reviewed, and governed, not merely switched on. Above all, programmes must withstand supervisory review, thematic inspections, and data-driven questioning, proving not only that controls exist, but that they are understood, applied, and capable of protecting the UAE’s financial system.
Impeccably Suited to the UAE
Compliance, like tailoring, fails when it is done off the rack.
AML programmes are structured around how UAE regulators test risk assessments, CDD files, sanctions screening logic, and transaction monitoring during inspections.
Our AML compliance frameworks are built specifically for entities operating under UAE AML Law, Federal Decree Law No. 10 of 2025, and Cabinet Resolution No. 134 of 2025. What “made for the UAE” looks like in practice:
- Separate AML frameworks for Mainland, Free Zone, ADGM, and DIFC entities, aligned to the supervisory approach of each authority rather than a single reused template.
- AML compliance for VASPs is built around wallet risk, custody models, and transaction behaviour, aligned with FATF Virtual Asset Guidance, VARA Rulebooks, SCA requirements, FSRA, and DFSA regimes.
- Controls designed to match real onboarding, transaction flows, alert handling, investigations, and goAML escalation processes.
This is GRC built for the UAE’s pace, its ambition, and its intolerance for surface-level compliance. We advise firms that intend to grow here, be supervised here, and remain credible long after their first licence approval. Get in touch with us to avail GRC Services in UAE.
Why AML/CFT Compliance Is Important?
AML compliance is a core regulatory requirement in the UAE and a key factor in licensing, supervision, and ongoing regulatory relationships. Regulators assess AML/CFT compliance to determine whether firms understand their financial crime risk and have controls in place to manage it effectively. Deficiencies can result in remediation directives, enhanced supervision, licence conditions, financial penalties, and reputational impact.
Strong AML/CFT compliance protects a firm’s ability to operate. Banks, regulators, and counterparties rely on the quality of AML frameworks when approving accounts, transactions, and regulatory permissions. Clear risk assessments, effective customer due diligence, and well-governed transaction monitoring reduce exposure to money laundering, sanctions breaches, and enforcement action.
For higher-risk sectors, including virtual assets, AML compliance is critical to regulatory approval and continued operation. VARA, SCA, ADGM FSRA, and DIFC DFSA expect AML/CFT compliance frameworks that are risk-based, proportionate, and actively maintained. For VASPs, AML compliance underpins VARA licensing and alignment with FATF Virtual Asset Guidance. In the UAE, AML/CFT compliance is not optional hygiene. It is a prerequisite for scale, stability, and regulatory trust.
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 AML/CFT Compliance Services
Our AML/CFT compliance services are where principle is given proper form and ceremony. Each service is considered and applied with discipline, shaped to meet the exacting gaze of UAE regulators. Together, they form a programme that is impeccably structured and perfectly prepared to account for itself when invited to do so.
ML/FT/PF Risk Assessment
We conduct business-wide risk assessments that identify exposure to money laundering, terrorist financing, and proliferation financing across the organisation.
- Coverage across customers, products, geographies, and delivery channels
- Documented methodology for inherent risk, controls, and residual risk
- Clear scoring logic aligned to UAE supervisory expectations
- Evidence pack prepared for regulatory inspection
AML Policies and Procedures
We draft and refine AML policies that translate regulatory requirements into operational discipline. These are documents written to guide decisions, define accountability, and demonstrate governance, not merely to satisfy form.
- Policies aligned to UAE AML law and regulator rulebooks
- Clear roles, responsibilities, and escalation pathways
- Procedures mapped to actual business processes
- Support through approval, roll-out, and review
Customer Risk Assessment
We design customer risk assessment models that support proportionate due diligence and consistent onboarding decisions. Each model is structured to explain why a customer is rated as they are, and what that rating requires in practice.
- Defined customer risk factors and weightings
- Transparent scoring methodology
- Triggers for SDD, CDD, and EDD clearly set
- Approval and override governance embedded
KYC and CDD Framework
We establish KYC and CDD frameworks that withstand file testing and supervisory challenge. The emphasis is on completeness, consistency, and traceability across onboarding and ongoing review.
- KYC templates and onboarding standards
- CDD and EDD checklists proportionate to risk
- Source of funds and source of wealth requirements
- Ongoing monitoring and periodic review cycles
PEP and High Risk Customer Management
PEPs and high-risk customers require structured oversight, not heightened anxiety. Our framework ensures such relationships are identified early, approved consciously, and reviewed regularly, with decisions recorded clearly. Risk is managed through process, not assumption.
- Identification of domestic, foreign, and international organisation PEPs
- Defined enhanced due diligence triggers and senior management approvals
- Ongoing monitoring, adverse media review, and scheduled reassessment
Sanctions Screening
Sanctions screening is treated as a continuous regulatory obligation, not a one-time control. Our screening programmes are designed to identify potential matches promptly and escalate them without delay. Resolution is governed, documented, and auditable.
- Screening against UAE, UN, and applicable international sanctions lists
- Coverage across onboarding, transactions, and ongoing customer activity
- Clear escalation timelines, hit resolution standards, and oversight
Name Screening Tuning
Screening systems require maintenance if they are to remain effective. We approach tuning as a controlled process, balancing detection accuracy with operational clarity. Every adjustment is justified and traceable.
- Calibration of thresholds and matching rules
- Controls addressing data quality and false positives
- Formal change governance, testing, and audit trails
Transaction Monitoring
Our transaction monitoring frameworks are designed around how risk actually manifests in the business. Scenarios and thresholds are calibrated to products, customer types, and transaction velocity. Governance ensures monitoring remains effective as business activity evolves.
- Scenario design covering structuring, velocity, geographic risk, and behavioural anomalies
- Threshold calibration linked to customer risk ratings and product profiles
- Periodic tuning, effectiveness testing, and management approval
Case Management
Our case management frameworks ensure alerts are investigated consistently and decisions are traceable. Responsibilities, timelines, and documentation standards are clearly defined. Every case can be reconstructed during regulatory review.
- Defined investigator roles, review layers, and decision authority
- SLAs for alert review, escalation, and closure
- Evidence standards, decision rationale, and audit trail requirements
STR and goAML Reporting
Our STR frameworks ensure suspicious activity is escalated, assessed, and reported in line with UAE requirements. Decisions are documented clearly and supported by evidence. Reporting is structured to withstand FIU follow-up.
- Internal escalation triggers and STR decision thresholds
- Narrative standards covering suspicion rationale and transaction context
- goAML submission timelines, approvals, and record retention
AML Training
Our AML training programmes focus on decision-making responsibilities, not regulatory theory. Content reflects real scenarios staff encounter in their roles. Training outcomes are documented and monitored.
- Board and senior management training on oversight and accountability
- Operational training on KYC, screening, monitoring, and escalation
- Attendance tracking, assessment results, and refresher scheduling
AML Internal Audit
Our AML internal audits test whether controls operate effectively under real conditions. Reviews focus on both design and execution. Findings are prioritised by regulatory risk.
- Testing of risk assessment, KYC files, screening, and monitoring alerts
- Review of STR decisions, narratives, and reporting timelines
- Risk-rated findings with clear remediation actions
AML Programme Remediation
Our remediation services address findings from regulators, audits, or internal reviews. Actions are prioritised and tracked through to closure. Evidence is prepared with supervisory review in mind.
- Gap analysis against regulatory findings and root cause assessment
- Corrective action plans with owners, timelines, and milestones
- Closure testing and documentation for regulator submission
AML Software Selection
Our software selection services ensure AML systems meet regulatory and operational needs. Selection decisions are evidence-based and defensible. Vendor bias is avoided.
- Requirements mapping across screening, monitoring, reporting, and case management
- Evaluation of data quality, scenario logic, scalability, and auditability
- Implementation planning, governance, and post-go-live review
AML Compliance, As UAE Sees It
We Advise on AML/CFT Compliance with a Clear Understanding of How Supervision Works in Practice across Mainland, Free Zones, and Financial Centres
Industries We Serve
Accountants and Auditors
Asset Managers & Investment Firms
DPMS
Insurance
Lawyers
Payments and Fintech
Real Estate
Securities & Brokerage
TCSPs
VASPs
Where Things Become Complicated
AML/CFT compliance pain points in the UAE emerge during day-to-day operations, when risk assessments, customer decisions, monitoring controls, and reporting obligations are applied under real regulatory scrutiny.
VARA Regulated Firms
- Customer risk models do not reflect wallet behaviour, transaction velocity, or cross-chain exposure
- Transaction monitoring scenarios lag behind emerging typologies and token movement patterns
- STR decisions are weakly evidenced when reviewed by VARA
DIFC Firms
- CDD standards applied inconsistently across onboarding and relationship teams
- Monitoring alerts closed without clear rationale or documented judgement
- PEP reviews treated as procedural rather than analytical under DIFC DFSA supervision
ADGM Entities
- Business risk assessments approved but not refreshed in line with activity changes
- Monitoring thresholds poorly aligned to customer risk ratings
- STR decisions overly dependent on individual judgement during ADGM FSRA reviews
SCA-Regulated Firms
- Alert backlogs caused by transaction volume and legacy monitoring tools
- Informal escalation of suspicious activity within business teams
- Delayed STR reporting identified by Securities and Commodities Authority
Mainland and Free Zone Companies
- KYC standards applied unevenly across departments and locations
- Customer risk ratings assigned mechanically without supporting rationale
- Unclear STR thresholds exposed during reviews by the Central Bank of the UAE and Ministry of Economy and Tourism
Why GRC Advisors Are a Sensible Choice?
When firms look for AML/CFT compliance support in the UAE, they often find consultancies that deliver documents or prepare them for a single review. Many of the leading AML consultants build frameworks that are technically sound and audit-ready, yet stop once implementation is complete. GRC Advisory takes a different view. We design AML/CFT compliance that can be examined repeatedly, adapts as the business grows, and remains credible long after the first inspection has passed. We:
- Design AML/CFT frameworks that align directly with obligations under Federal Decree Law No. 10 of 2025 and Cabinet Resolution No. 134 of 2025, not generic international summaries.
- Document risk decisions to meet the evidentiary standards expected by the Central Bank of the UAE and UAE supervisory authorities during inspections and enforcement reviews.
- Structure AML governance to reflect the personal accountability placed on boards, MLROs, and senior management under UAE law.
- Align transaction monitoring, escalation, and STR processes with how the FIU reviews submissions through goAML, including follow-up and clarification cycles.
- Design programmes with regulator behaviour in mind, drawing on supervisory practices of VARA, ADGM FSRA, and DIFC DFSA.
- Prepare firms for AML/CFT compliance as a continuing legal obligation.
The Long View of AML Compliance
AML/CFT Advisory Built for Sustained supervision