AML/CFT/CPF Policies and Procedures for UAE Businesses
AML policies that reflect how your business really operates.
Your AML policy should reflect how your business operates. Adventant prepares and updates AML, counter-terrorist financing (CFT), counter-proliferation financing (CPF) and sanctions policies and procedures that set out the checks employees must complete, who handles concerns and how decisions are recorded, so your team has clear instructions for daily work.
Who it is for: New businesses building an AML framework, and firms whose existing policies are generic or out of date.
What should an AML policy cover?
A policy sets out your approach to AML and counter-terrorist financing: roles and responsibilities, customer due diligence, screening, monitoring, reporting, training and record-keeping. Procedures turn that into step-by-step instructions for staff. Both should match your activities, customers and regulator rather than a generic template.
The compliance challenge
A template policy rarely matches how a business actually works. Staff either ignore it or follow it inconsistently, and the gaps appear in a review.
Policies also go stale when the business, its customers or the rules change. A policy that does not match practice is a weakness, not a safeguard.
What the service includes
- Drafting or refreshing AML, CFT, CPF and sanctions policies
- Writing procedures that match your activities, systems and regulator
- Defining roles, approval levels, escalation routes and reporting lines
- Setting out customer due diligence, screening and monitoring steps
- Aligning documents with your business-wide risk assessment
- Preparing templates, checklists and registers that staff will actually use
- Reviewing and updating documents as your business or the rules change
Scope and boundaries
- Policies are drafted for your business and approved by your management and appointed officer.
- Written procedures only help if staff apply them, so training and compliance monitoring are separate steps.
- We reflect the requirements that apply to your licence but do not provide legal advice.
How the engagement works
- 01
Understand your business
Learn how you onboard, serve and monitor customers day to day.
- 02
Review existing documents
Identify what works, what is missing and what no longer matches practice.
- 03
Draft policies and procedures
Write documents tailored to your activities, systems and regulator.
- 04
Embed and approve
Agree roles and escalation routes, obtain approval and brief the team.
- 05
Maintain and update
Review on a schedule and whenever the business or the rules change.
Who needs this service
- New businesses building an AML framework
- Firms with generic or outdated policies
- Businesses changing products, customers or markets
- Teams preparing for a review or inspection
Requirements depend on your supervisor and licence category. Start with the page for your regulator:
Regulatory context
Supervised businesses are expected to maintain documented AML and counter-terrorist-financing policies, controls and procedures that are proportionate to their risks, approved by senior management and kept up to date.
Supervisors may publish sector-specific guidance on what policies should contain. Check the guidance issued for your licence category.
General information, not legal advice. Check current requirements with your supervisor.
Frequently asked questions
Can we just use a template?
A template is a starting point at best. Procedures work when they reflect your activities, systems and customers, so we tailor them to how you operate.
How often should policies be reviewed?
Regularly, and whenever your services, customers or the applicable rules change. Follow any specific review period set by your regulator.
Who approves the policy?
Senior management, on the recommendation of your Compliance Officer or MLRO, in line with your governance.
Do policies need to match the risk assessment?
Yes. Controls should respond to the risks you identify, so we align the two.
Other services
Outsourced MLRO Service
Experienced oversight where an external appointment is permitted.
Governance Support for Your MLRO
Support for the team you already have.
Operational Outsourcing
Screening, customer risk assessment and ongoing monitoring, handled for you.
Independent AML Audits / Reviews
Independent assurance over your controls.
Regulatory Inspection Support
Support before, during and after regulatory scrutiny.
goAML Registration and Reporting
goAML registration, EOCN subscription, report filing and semi-annual reports.
Grievance Filing (Fine Waiver)
A clear, evidenced grievance against an AML penalty.
Enterprise-Wide Risk Assessment
Understand where your real risk sits.
AML Training
A team that understands its responsibilities.
AML Software (TruDiligent)
TruDiligent, set up around your compliance process.