What Are Internal Control Services
Internal controls are the small disciplines that keep a business steady.
They decide who checks, who approves, and what is recorded. They shape how decisions are made and how actions are confirmed. When someone asks how a risk is managed, internal controls provide the answer without hesitation.
In the UAE, expectations around internal control have grown precise. Regulators look for consistency, clear ownership, and evidence that reflects how the business truly operates.
An Internal Control Process introduces order into daily activity. It anticipates where errors or misuse may occur and embeds simple, deliberate checks into routine operations.
At GRC Advisory, we work with internal controls as a structured Internal Control Process. We review how controls function, document them clearly, test their effectiveness, correct weaknesses, and strengthen the evidence that supports them.
Crafted for the UAE Regulatory Eye
Internal controls in the UAE are shaped by how authority observes, questions, and concludes.
Supervision here is attentive and practical. Whether a firm is overseen by VARA, the Securities and Commodities Authority, the ADGM Financial Services Regulatory Authority, or the DIFC Dubai Financial Services Authority, internal controls are examined through their conduct, not their claims.
For Mainland entities, expectations are reinforced through the Central Bank of the UAE, with inspections and guidance shaped by the Ministry of Economy and Tourism and the Ministry of Justice. Newer structures, including RAK DAO, place further emphasis on clarity as businesses mature.
Our Internal Control Frameworks are built with this method of supervision in mind.
They are designed to:
Sit comfortably within the UAE AML Law, Federal Decree Law No. 10 of 2025, and Cabinet Resolution No. 134 of 2025
Align with supervisory expectations reflected in the CB UAE AML CFT Rulebook and relevant ministerial guidance
Translate international standards, such as FATF Virtual Asset Guidance and IOSCO Crypto Asset Principles, into controls that operate meaningfully under local regimes
Reflect how digital and virtual asset oversight is applied through the FSRA Virtual Asset Framework, the DFSA Crypto Token Regime, the DIFC Digital Assets Law, and the VARA Rulebooks
In practice, this means internal controls that are clearly owned, consistently applied, and supported by evidence that requires no explanation. Controls must work across teams and systems, and remain steady under inspection.
At GRC Advisory, our Internal Control Process is developed with this environment in mind. We design controls that recognise how supervision unfolds in the UAE, how questions are asked, and how assurance is formed.
Internal controls built for this market are composed, deliberate, and quietly persuasive.
Why are Internal Controls Important?
Internal controls are important because they allow a business to grow without losing its composure.
In the early days, decisions are instinctive. Approvals happen quickly. Oversight lives close to the founder. This works for a time. As the business expands, the same closeness begins to strain.
Internal controls introduce order without heaviness. They clarify who decides, who reviews, and who confirms. They allow responsibility to be shared without authority becoming diluted.
In the UAE, this shift arrives earlier than many founders expect. Growth brings visibility. Visibility brings review. What once functioned on trust alone is expected to show structure.
A Well-considered internal control process:
Reduce reliance on individual presence and judgment
Create steadiness as teams and operations expand
Prevent small issues from returning as familiar problems
Support credible AML and governance arrangements
Allow founders to step back without losing sight
For regulated firms and VASPs, internal controls carry added significance. Licensing, supervision, and external confidence rest on the same quiet discipline. Investors notice it. Boards depend on it.
When internal controls are in place, the business keeps its shape as it grows.
Our Internal Controls Services
Internal control process is the art of order. It decides who may act, how actions are checked, and what evidence remains when questions are asked. In the UAE’s regulatory landscape, internal controls are read closely. They are not admired for ambition, only for discipline.
Our internal control services help organisations build control environments that are thoughtful, proportionate, and inspection-ready. We design controls that fit the rhythm of the business, document them with care, and test them with a clear regulatory eye across DIFC, ADGM, VARA, SCA, Mainland, and Free Zones.
Internal Control Framework
A control framework is the grammar of governance. It gives structure to risk, authority, and accountability. We design frameworks that are clear, usable, and aligned to GRC expectations.
- Design and refinement of internal control frameworks
- Development of structured control libraries linked to risk
- Definition of entity-level and process-level controls
Controls Documentation
What is not written is rarely remembered. We document controls so they can be understood, followed, and defended.
- Process mapping that reflects real workflows, not idealised charts
- Control narratives defining purpose, frequency, ownership, and evidence
- Risk and control matrices structured for audit and regulatory review
Controls Testing
Controls reveal their strength only when examined. We test with patience and precision, focusing on how controls actually operate. Our testing mirrors the expectations of internal audit and regulators.
- Risk-based testing methodologies proportionate to the control environment
- Walkthroughs to confirm design effectiveness and staff understanding
- Sampling and operating effectiveness testing with clear grading of findings
Root Cause and Fixes
- A weak control is a question waiting to be asked again. We look beyond the symptom and address the reason it exists.
- Structured root cause analysis linked to governance, process, or people issues
- Design of practical remediation plans aligned to risk appetite
- Support with ownership, timelines, and sustainable implementation
Evidence Standard
Evidence is the language through which controls speak. When evidence is inconsistent, assurance weakens. We define evidence standards that support credibility and consistency.
- Clear evidence expectations aligned to audit and regulatory standards
- Design of audit trails, approval flows, and management sign-offs
- Record retention guidance and sample evidence packs for inspections
A Conversation Worth Having
If Your Controls Are Due for Examination or Refinement, We Are Ready to Listen and Advise with Care
Accountants and Auditors
Asset Managers & Investment Firms
DPMS
Insurance
Lawyers
Payments and Fintech
Real Estate
Securities & Brokerage
TCSPs
VASPs
Where Internal Controls Begin to Strain
DIFC and ADGM Regulated Entities
- Control frameworks exist, yet alignment with DFSA or FSRA expectations has softened over time
- Entity-level controls rely heavily on senior individuals, with limited documentation or succession
- Licensing-stage control documentation has not matured alongside the business
- Evidence supporting key controls is inconsistent across review periods
- Internal control testing is informal or mistaken for internal audit
VARA Licensed and Virtual Asset Firms
- Business growth has outpaced the development of structured controls
- Policies exist, but execution and evidence remain uneven
- Segregation of duties is weak across custody, wallet management, and approvals
- Technology and operational controls are insufficiently tested
- Evidence packs are incomplete, fragmented, or prepared too late
SCA Regulated Firms
- Control frameworks reflect traditional operations, with limited adaptation to digital activity
- Risk assessments do not clearly inform control design
- Manual controls dominate, with minimal oversight or documentation
- Remediation actions remain open across successive reviews
- Evidence retention practices fall short of inspection expectations
UAE Mainland and Free Zone Companies
- Internal controls are informal, undocumented, or inconsistently applied
- Operational reliance on trusted individuals replaces structured oversight
- Evidence expectations are poorly understood until an audit begins
- Control failures surface late, often during statutory audit or due diligence
- No established approach to testing or root cause analysis
Growing and Transitioning Organisations
- Controls designed for a smaller organisation no longer scale with activity
- Governance structures exist in form, but not in daily practice
- Remediation is reactive, driven by findings rather than foresight
- Control ownership becomes blurred across functions and jurisdictions
Why GRC Advisors
Clients choose us for counsel that is informed and for work that prioritises permanence over persuasion.
- First-hand experience across DIFC, ADGM, VARA, SCA, Mainland, and Free Zones, shaped by direct involvement in regulatory reviews and supervisory dialogue
- An approach informed by how regulators assess substance, select samples, and form judgment, rather than by generic compliance models
- Integrated understanding of governance, risk, AML, and virtual asset regulation, allowing frameworks to align rather than compete
- Work led by seasoned practitioners who remain involved throughout, ensuring consistency of thought and execution
- Careful attention to evidence, records, and audit trails, recognising that assurance rests as much on proof as on process
Resolution of issues through considered diagnosis, addressing underlying causes rather than recurring symptoms
Before Questions Are Asked
Strong Controls Speak First and Most Convincingly. We Help You Get There