AML Compliance Inspections

If you're the CEO or owner of a real estate firm in the UAE, you are accountable, not just in name, but in law.

While compliance officers handle the day-to-day tasks, it’s your license, your money, and your business reputation that’s at risk during an AML inspection.

This guide is designed to give you a clear, direct roadmap of what to do, what to avoid, and how to take control, before the Ministry of Economy comes knocking.

What You Must Do - As a CEO

1. Know What Inspectors Expect
   • Understand what AML inspectors (MoE) are authorized to review.
   • Familiarize yourself with the required documents and processes (see checklist below).
2. Personally Review Your AML Policy
   • Don’t assume someone else took care of it. Read the document.
   • Ensure it includes UAE-specific obligations: goAML reporting, sanctions screening, customer risk rating, and internal reporting procedures.
3. Demand Evidence of Implementation
   • Ask your compliance officer to show:
     • Proof of goAML registration
     • Last STR/SAR filed (if any)
     • Risk-based assessments and KYC files
     • Screening logs (UAE + UN sanctions lists)
     • Training records for staff
4. Run a Mock Inspection Internally
   • Simulate an inspection. Ask tough questions. Review the response.
   • Use this to surface gaps, don’t wait for the inspector to find them.
5. Make Sure Compliance Is Budgeted, Not Just Delegated
   • Provide the tools: AML software, screening access, risk scoring templates.
   • Compliance is a cost center, but fines are far more expensive.

What You Must Avoid

1. Don’t Say “That’s My Compliance Officer’s Job”
   • Regulators won’t accept it. You are legally responsible.
2. Don’t Assume You’re Safe Because You Registered on goAML
   • Registration is step one. Implementation is everything.
3. Don’t Tolerate Vague Answers
   • If you ask “how do we screen for sanctions?” and the answer is unclear, that’s a red flag.
4. Don’t Wait for a Fine to Take Compliance Seriously
   • Most violations come from neglect, not bad intent. Fix weak points now.
5. Don’t Rely on Memory, Require Documentation
   • Always ask to see written records, not just verbal confirmations.

AML Inspection Readiness Checklist for UAE CEOs

To avoid surprises during an AML inspection, make sure your business is audit-ready with the following core items:

Registration & Governance

• goAML Registration: Proof of goAML registration and login access (Inspectors check if your account is active and used.)
• AML Policy: Most recent AML Policy (dated and approved) (Outdated or generic policies are red flags.)

Risk & Client Documentation

• Risk Assessment Matrix: Risk-Based Assessment Matrix and client classifications (Inspectors assess how you rank and handle different risk levels.)
• KYC Records: KYC files for a sample of clients (with IDs, SoF, SoW) (This is often spot-checked.)

Screening & Monitoring

• Sanctions Screening: Sanctions screening records (UAE + UN lists) (Must be up-to-date and traceable.)
• PEP Screening: PEP screening history (PEPs are not always sanctioned, but high-risk.)

Training & Reporting

• Training Records: AML training log for all relevant staff (Inspectors will want to see who was trained and when.)
• SAR/STR Register: STR/SAR register (if applicable) (Even if you haven’t filed, your process must be documented.)
• Internal Escalation: Internal reporting/escalation policy (The link between your front-line and your compliance officer.)

🧠 Pro Tip: Review this checklist quarterly. Don’t wait for an inspection notice.

Take Control Before the Inspector Does

Being prepared isn’t just about avoiding penalties, it’s about protecting your brand, your clients, and your license to operate in one of the most regulated real estate markets in the region.

You don't need to become a compliance expert, but you do need to lead like one.

InfoAML is built for real estate firms in the UAE, with tools that make it easy to stay compliant, screen clients, maintain audit trails, and document every step of your AML process.

👉 Ready to upgrade your AML readiness? Get in touch with us at InfoAML.

You might find the following related blogs helpful:

→ How to Choose AML Software in the UAE: 5 Factors That Matter

→ Best AML Compliance Tools for DNFBPs in the UAE – 2025 Guide

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