Enterprise-Wide AML Risk Assessment in the UAE
Know where your real AML risk sits.
Adventant reviews your business activities, customer base and countries of operation to identify potential money laundering and terrorist financing risks. We also help assess individual customers, document their risk ratings and decide which relationships need closer attention or additional checks.
Who it is for: Businesses preparing a business-wide risk assessment, entering new markets or products, or rating customers consistently.
What is an enterprise-wide risk assessment (EWRA)?
An enterprise-wide risk assessment, also called a business-wide risk assessment, identifies how your business could be used for money laundering or terrorist financing, based on your customers, geographies, products and delivery channels, and judges whether your controls respond to those risks. A customer risk assessment applies the same thinking to each customer to set the level of due diligence and monitoring.
The compliance challenge
A risk assessment that sits in a drawer adds little. The value comes from using it to decide onboarding rules, monitoring and review frequency, and from being able to show the reasoning.
Many businesses rate customers by habit rather than by a clear method, so similar customers end up treated differently.
What the service includes
- Assessing business-wide risk across customers, geographies, products, services and delivery channels
- Reviewing the controls that respond to each risk and the residual risk that remains
- Designing a customer risk rating method that staff can apply consistently
- Assessing and documenting individual customer risk ratings
- Identifying relationships that need enhanced due diligence
- Recording your risk appetite and the reasoning behind it
- Producing a clear, defensible written assessment
Scope and boundaries
- Risk ratings and risk appetite are decisions for your management and appointed officer. We provide structure and challenge.
- An assessment reflects your business at a point in time and needs updating when it changes.
- We use the requirements and guidance that apply to your licence category as the starting point.
How the engagement works
- 01
Map your business
Document your customers, geographies, products and delivery channels.
- 02
Identify and rate inherent risk
Assess where the business is most exposed before controls are considered.
- 03
Review the controls
Test whether existing controls respond to each identified risk.
- 04
Document residual risk and appetite
Record what remains, what you accept and what needs action.
- 05
Apply and update
Feed the results into onboarding, monitoring and review, and refresh them as things change.
Who needs this service
- Businesses preparing their periodic business-wide risk assessment
- Firms entering new markets, products or customer types
- Teams that need a consistent customer risk rating method
- Businesses preparing for a regulatory review
Requirements depend on your supervisor and licence category. Start with the page for your regulator:
Regulatory context
A risk-based approach sits at the centre of UAE AML requirements: supervised businesses are expected to identify, assess and understand their money laundering and terrorist financing risks and to apply controls in proportion. Supervisors may set expectations for how often the assessment is reviewed and what it should cover.
National and sector risk assessments published by UAE authorities can inform your own. Check the material relevant to your sector.
General information, not legal advice. Check current requirements with your supervisor.
Frequently asked questions
How often should the assessment be updated?
Regularly, and whenever your business changes materially, for example through new products, markets or customer types. Your regulator may set a minimum frequency.
How do customer risk ratings work?
You rate each customer using factors such as who they are, where they operate, what they use and how they were onboarded. The rating then drives the level of due diligence, monitoring and review frequency.
Does the assessment replace our policies?
No. It informs them. Policies and controls should respond to the risks the assessment identifies.
Who signs off the assessment?
Senior management, on the recommendation of your appointed officer.
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.
AML / CFT / CPF Framework
Policies and procedures reflecting your actual work.
AML Training
A team that understands its responsibilities.
AML Software (TruDiligent)
TruDiligent, set up around your compliance process.