Building an Internal AML Audit Checklist for Your Sector

Introduction

In the UAE, AML inspections are becoming more frequent and more thorough. For DNFBPs, from real estate brokers to gold dealers, waiting for an inspection notice before reviewing your AML processes is risky business.

An internal AML audit checklist is your best defense. It keeps your compliance program running smoothly year-round, ensures your documentation is complete, and makes you inspection-ready on any day of the year.

This blog will help you create a sector-specific AML audit checklist so you can identify gaps before regulators do.

Why a Sector-Specific AML Checklist Matters

While the UAE AML framework applies to all DNFBPs, the risks, processes, and triggers vary by sector.

• Real estate brokers must handle REAR triggers and document high-value transactions.
• Developers may receive direct payments and need extra focus on source of funds.
• Gold & precious metals dealers face high cash transaction risks.
• Corporate service providers need detailed beneficial ownership mapping.

A generic checklist is better than nothing, but a sector-specific checklist ensures you’re covering the risks that apply to your exact operations.

Core AML Audit Checklist Items (For All Sectors)

These are non-negotiables every DNFBP should audit:

1. Policies & Procedures

• Up-to-date AML/CFT Policy (signed and approved)
• Risk Assessment Policy tailored to your business
• Procedure for CDD, EDD, STR/SAR/REAR reporting

2. Customer Due Diligence (CDD)

• Complete KYC/KYB documentation for all clients
• Screening logs for sanctions, PEPs, and adverse media
• Documented risk scoring for each client

3. goAML Reporting

• Proof of STR/SAR/REAR submissions
• Internal reports for cases reviewed but not reported
• Draft reports saved for audit purposes

4. Ultimate Beneficial Ownership (UBO)

• UBO declaration forms on file
• Proof of verification of UBO identity
• Updated UBO records for corporate clients

5. Training Records

• Staff AML training attendance logs
• Certificates or proof of completion
• Training materials archived

6. Transaction Monitoring

• Logs of unusual or high-value transactions
• Follow-up notes on alerts or red flags
• Evidence of enhanced due diligence where applicable

7. Internal Review Logs

• Records of monthly/quarterly compliance reviews
• Evidence of corrective actions taken
• Management approval of audit results

Sector-Specific Audit Points

Real Estate Brokers

• REAR trigger identification process documented
• Records of cash or crypto transactions ≥ AED 55,000
• Buyer/seller PEP checks on every deal

Real Estate Developers

• Source of funds verification for all direct buyers
• Payment plan and escrow account compliance checks
• Procedures for off-plan sales risk assessment

Gold & Precious Metals Dealers

• Cash transaction logs with customer ID copies
• Metal sourcing documentation and supplier verification
• Enhanced due diligence for cross-border deals

Corporate Service Providers

• Detailed beneficial ownership mapping for all clients
• Ongoing monitoring of shelf companies
• Screening of directors, shareholders, and associates

How to Use the Checklist Effectively

• Monthly: Quick checks of CDD files, screening logs, and transaction alerts.
• Quarterly: Deeper review of all high-risk clients and policy updates.
• Annually: Full internal audit covering every checklist item.
• Event-driven: Immediate review when regulations change or risk profiles shift.

Pro Tip: Link each checklist item to a supporting evidence file, so if an inspector asks, you can show proof instantly.

Sample Internal AML Audit Checklist

Area	Item	Evidence	Status
Policies	AML/CFT policy approved & signed	Policy file	Completed
CDD	All client files screened for PEPs	Screening logs	Missing
Reporting	STR/SAR proofs saved	goAML receipts	Pending Review
Training	Staff trained in last 12 months	Certificates	Completed
...	...	...	...

How InfoAML Helps

When it comes to internal AML audits, having the right system makes all the difference. InfoAML already covers many of the key points in a typical audit checklist, such as storing client files, screening logs, goAML reporting records, and linking audit items with supporting evidence. This makes it easier for compliance officers to demonstrate compliance and produce inspection-ready records quickly.

Conclusion

An internal AML audit checklist is your compliance safety net. By tailoring it to your sector and using it regularly, you can spot issues before they become violations, and pass inspections with confidence.

You might find the following related blogs helpful:

The Complete AML Inspection Readiness Checklist for UAE Businesses: Everything You’ll Be Asked For

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