Key areas to consider in response to the UAE’s AML requirements

As the UAE’s Anti-Money Laundering requirements continue to evolve, MLROs and Compliance Officers play an important role in ensuring that their Boards and Executive Teams respond effectively to the regulator’s expectations in relation to governance and oversight. 

Specific actions that firms should consider include:

• Carry out a gap analysis of your firm’s Business-Wide Risk Assessment (BWRA) against the 2025 Law and Executive Regulations
• If appropriate, include risks relating to cryptocurrencies, gaming transactions and new types of regulated business
• Consider further granularity and evidence-based outcomes

• Ensure that you have documentary evidence demonstrating the links between the BWRA, controls, monitoring and reporting
• Validate that Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD), transaction monitoring and screening reflect actual risk exposure based on activity and outcomes

• Ensure that beneficial ownership controls focus on verified and refreshed beneficial ownership intelligence, rather than just declared data
• Utilise UBO controls that are initiated by triggers

• Ensure that proliferation finance is treated as a standalone risk within the BWRA, the firm’s policies and procedures, and its approach to monitoring
• Where appropriate, incorporate trade-based typologies, dual-use goods and sanctions evasion risks
• Report financial crime exposure incidents to the Board

• Ensure that the MLRO has direct access to the Board as needed
• Identify and escalate resource gaps and any conflicts with MLRO independence
• Obtain clarity from the Board of the financial crime risk appetite
• Support the Board in understanding all material risks, associated controls and mitigation strategies, and key metrics and markers to assess control effectiveness

• Move beyond metrics that simply report activity, embedding effectiveness measures across inputs, quality, and outcomes to provide a more meaningful picture of control performance
• Strengthen Board support mechanisms to enable senior management to demonstrate clear oversight and effective control of financial crime risks
• Identify, implement and track control adequacy and weaknesses

‘‘The UAE is committed to staying ahead of emerging threats through continuous enhancement of our AML/CTF framework, ensuring our financial system remains safe, resilient, and efficient.” - His Highness Sheikh Abdullah bin Zayed Al Nahyan 

To explore these themes in detail through in-person and virtual training, from live Senior Management briefings, courses for MLROs and FCC staff or eLearning for your front and back office, get in touch.