KYC and CDD Framework Services
KYC and CDD services establish the foundation of disciplined client onboarding.
KYC, or Know Your Customer, verifies identity through reliable documentation, confirms legal existence for corporate entities, and validates authorised signatories. CDD, or Customer Due Diligence, examines beneficial ownership, the purpose of the relationship, the origin of funds, and the client’s overall risk profile. Where exposure is elevated, Enhanced Due Diligence applies deeper verification and documented analysis.
A well-designed KYC and CDD framework integrates standardised templates, structured CDD and EDD checklists, defined risk rating methodology, source of funds and source of wealth validation steps, escalation thresholds, approval governance, and ongoing monitoring protocols.
KYC establishes identity.
CDD determines exposure.
Together, they create a consistent, defensible approach to client risk management.
Stop Carrying Compliance Risk Alone
Strengthen Your KYC and CDD Controls with Our GRC Advisory Team
The Regulatory Position in the UAE
Regulators across ADGM, DIFC and Mainland jurisdictions apply a risk-based approach rooted in the UAE AML framework. The message is consistent. Firms must know their customers, understand beneficial ownership, assess risk exposure, and document their reasoning with clarity.
The Financial Services Regulatory Authority expects firms in ADGM to demonstrate structured client risk assessment supported by verifiable documentation.
The Dubai Financial Services Authority examines whether due diligence is proportionate, risk-driven, and embedded into governance processes rather than applied selectively.
The Virtual Assets Regulatory Authority applies detailed scrutiny to onboarding controls under its Rulebooks, particularly around beneficial ownership transparency and digital asset exposure.
The Securities and Commodities Authority focuses on ownership clarity and the integrity of market participants.
The Central Bank of the UAE requires institutions to demonstrate systematic customer identification, monitoring, and sanctions controls under its AML CFT Rulebook.
Across these supervisory bodies, expectations converge around several non-negotiables:
• A documented and logical customer risk assessment methodology
• Clear differentiation between standard and enhanced due diligence
• Proper identification and verification of Ultimate Beneficial Owners
• Credible source of funds and source of wealth analysis
• Effective sanctions, PEP, and adverse media screening
• Ongoing monitoring aligned to the assigned risk rating
• Complete audit trails and record keeping
In the UAE, the standard is simple.
If your KYC confirms identity but your CDD cannot justify the risk rating, the framework is weak. If your documentation cannot explain your decision, it will not withstand inspection.
Common Failures in KYC and CDD Implementation
On paper, the framework appears complete, with policies drafted, templates circulated, and risk ratings formally assigned to each client. However, when subjected to inspection, inconsistencies emerge quickly, and the absence of structured reasoning becomes evident.
The most common weaknesses we identify during GRC Advisory reviews include the following.
Risk ratings are often assigned without a defined scoring methodology, meaning clients are categorised as low, medium, or high risk without any documented logic to justify the conclusion.
Beneficial ownership structures are recorded but not fully analysed, and source of funds or wealth is described without sufficient independent verification or supporting evidence.
Enhanced Due Diligence is triggered late, typically after concerns arise, rather than through predefined escalation criteria applied at onboarding.
Screening processes are treated as automated exercises, where sanctions and PEP tools generate alerts, but there is no structured review methodology to interpret and document the outcome
Individual client risk scoring does not meaningfully reflect the organisation’s broader AML risk assessment, creating inconsistencies in exposure management.
Periodic reviews are formally scheduled but not rigorously enforced, leading to stale files where risk profiles evolve while documentation remains unchanged.
Strong Compliance Rarely Makes Headlines
Build a KYC and CDD Framework That Keeps It That Way
How We Build Your KYC and CDD Framework
A robust KYC and CDD framework is built through structure, sequencing, and disciplined oversight. Each phase must connect logically to the next, ensuring that risk is identified, assessed, approved, and monitored with consistency. Our methodology follows a clear progression designed to produce defensible decisions and inspection-ready documentation.
Risk Framework Design and Amendment
Every credible KYC and CDD framework begins with a defensible risk model.
We start by analysing your business model, customer segments, product lines, delivery channels, and geographic exposure. From there, we identify the specific risk variables that genuinely apply to your operations and design a structured risk scoring matrix.
Each variable is calibrated to ensure proportionality. Low-risk relationships are not overburdened, and higher-risk profiles cannot slip through under broad classifications.
Onboarding and Data Collection
Once the risk architecture is established, we implement disciplined onboarding controls.
We develop or refine your KYC templates, CDD checklists, and UBO declaration forms to ensure that information collected is relevant, complete, and aligned with your risk methodology.
We map beneficial ownership through documentary evidence, Where shareholding chains are complex, we analyse control rights, voting structures, and indirect ownership until Ultimate Beneficial Owners are clearly identified.
All documentation is captured in a structured format designed to create clear audit trails and minimise inconsistencies across files
Screening, Risk Assessment, Escalation
We conduct sanctions, Politically Exposed Persons, and adverse media screening using calibrated tools configured to reflect your risk exposure and jurisdictional footprint.
Alerts are reviewed through a documented evaluation process that distinguishes false positives from material risk indicators. Using the calibrated scoring matrix, we calculate the client’s overall risk rating.
Where predefined thresholds are met, Enhanced Due Diligence is triggered automatically.
Quality Assurance and Approval
Before any onboarding decision is finalised, the file undergoes structured quality assurance. We examine whether:
- All required documentation has been obtained and verified
- Beneficial ownership has been fully mapped and evidenced
- Source of funds and source of wealth analysis is proportionate and supported
- Screening alerts have been resolved with documented reasoning
- The assigned risk rating aligns with the scoring methodology
- Enhanced Due Diligence, where applicable, has been properly applied
Where inconsistencies are identified, the file is returned for remediation before approval.
Ongoing Monitoring and Periodic Review
We implement risk-based monitoring aligned to the client’s classification. Higher-risk clients are subject to more frequent review cycles, expanded transaction scrutiny, and recurring screening.
Periodic reviews reassess:
- Changes in ownership or control
- Variations in transaction behaviour
- Jurisdictional exposure shifts
- New adverse media or sanctions developments
- Updated source of funds or wealth information
This ensures that your KYC and CDD framework functions as a living control environment rather than a static onboarding archive
Serious Compliance. Serious Advantages
A strong KYC and CDD framework does more than satisfy regulatory expectations. It gives compliance teams the confidence to approve, escalate, and defend decisions without hesitation. It replaces ambiguity with structure and instinct with documented reasoning.
A documented risk methodology that aligns client risk ratings with your enterprise AML risk assessment.
Complete and evidenced UBO identification, even in layered or complex ownership structures.
Source of funds and source of wealth analysis supported by proportionate documentation.
Sanctions and PEP screening supported by recorded alert resolution and audit trails.
Independent quality assurance review before onboarding approval.
Trigger-event reassessment procedures embedded into onboarding governance.
Make Every Onboarding Decision Defensible
We Design KYC Services and CDD Services That Protect Boards, Support MLROs, and Satisfy UAE Supervisory Authorities