Regulatory Requirements
Identify the applicable AML legislation, supervisory guidance, and sector-specific requirements relevant to your business.
AML Governance and Documentation
AML Policies and Procedures for Your Business
Establish a clear, documented approach to anti-money laundering compliance. Develop policies and procedures that reflect your business activities, risk exposure, internal responsibilities, and applicable regulatory requirements.
Documented controlsDefined responsibilitiesOngoing reviews
POLICY FRAMEWORK
Compliance in Practice
1
Written policies and procedures2
Clear employee responsibilities3
Documented escalation processes4
Regular review and improvement
Clear Documentation
Policies designed around applicable requirements
Why Policies Matter
Turn AML Requirements Into Clear Business Procedures
AML policies establish the principles and responsibilities that guide an organisation's compliance framework. Procedures explain how employees apply those principles during everyday business activities.
Together, they help create consistency in customer checks, risk assessment, suspicious activity escalation, record keeping, and internal oversight.
Set consistent expectations across relevant teams.
Clarify ownership of AML tasks and decisions.
Support appropriate customer checks and monitoring.
Provide a documented basis for reviews and improvements.
Core Policy Areas
What Should an AML Policy Framework Cover?
The framework should reflect the organisation's risk profile and the requirements that apply to its activities. Relevant policy areas may include the following.
Roles and Responsibilities
Define who is responsible for compliance oversight, customer checks, internal escalation, record keeping, and policy reviews.
Customer Due Diligence
Set out procedures for customer identification, verification, beneficial ownership checks, and enhanced due diligence where required.
Suspicious Activity Escalation
Establish clear internal processes for identifying, documenting, escalating, and reporting suspicious activity when required.
Record Keeping and Access
Document appropriate arrangements for maintaining, protecting, retrieving, and retaining relevant compliance records.
Monitoring and Review
Define how policies are reviewed, how control gaps are addressed, and how changes in risks or applicable requirements are incorporated.
Documentation Framework
Essential AML Policies and Supporting Procedures
The documentation required will depend on your business, risk assessment, and applicable regulatory obligations. Common policy and procedure areas can include:
AML Policy
A documented overview of the organisation's AML framework, governance, and control principles.
Customer Due Diligence Procedures
Procedures for customer identification, verification, risk classification, and ongoing due diligence.
Suspicious Activity Procedures
Internal processes for recognising concerns, escalating cases, and making reports through the appropriate channels.
Record Retention Procedures
Guidance on maintaining and retrieving relevant customer, transaction, and compliance records.
Training and Awareness Plan
A framework for communicating responsibilities and providing suitable AML training to employees.
Review and Escalation Framework
Arrangements for reporting control gaps, assigning corrective actions, and reviewing policy effectiveness.
Our Approach
From Policy Development to Implementation
A structured process helps turn written policies into practical procedures that employees can understand and follow.
01
Understand Your Business
Review business activities, customers, services, delivery channels, and applicable regulatory requirements.
02
Develop Written Policies
Document suitable AML controls, procedures, responsibilities, and escalation arrangements.
03
Implement Procedures
Communicate requirements to relevant employees and establish practical processes for day-to-day compliance.
04
Review and Update
Assess whether the framework remains appropriate and update documentation when necessary.
Ongoing GovernanceDiscuss Your Requirements
Keep Your AML Policies Relevant as Your Business Changes
Policies should not remain static. Changes in business activities, customer risk, internal controls, or applicable regulatory requirements may mean that procedures need to be reviewed and updated.
Review policies at appropriate intervals.
Assess the impact of relevant regulatory changes.
Communicate updated procedures to employees.
Document reviews and follow up on identified gaps.
Important Compliance Note
This page provides general information and is not legal advice. The appropriate AML policies and procedures depend on the applicable UAE legal framework, supervisory authority, sector, and individual business circumstances. Confirm the requirements applicable to your organisation before adopting a policy framework.
Strengthen Your Compliance Framework
Contact Our TeamBuild Clear, Practical AML Policies for Your Business
Discuss your existing documentation, business activities, and policy development requirements with our team.