Introduction
Inspections are no longer a rare event, they’re a certainty. If you’re operating in the UAE as a real estate broker, gold trader, or any other DNFBP, you’re subject to Anti Money Laundering (AML) inspections under Federal Decree-Law No. (20) of 2018 and Cabinet Resolution No. (10) of 2019.
Whether you're a CEO responsible for governance, an MLRO managing daily controls, or a compliance officer keeping files in order, this guide walks you through everything inspectors will ask for.
Let’s get you inspection-ready.
Section 1: Company Information
- Trade License, Memorandum & Articles of Association
Clarification: These foundational documents prove your legal existence and scope of operations.
- Shareholder/UBO register
Clarification: Identifies who truly owns and benefits from your company.
- Organizational chart and staff list with designations and nationalities
Clarification: Helps inspectors understand reporting lines and who is responsible for AML.
- Group structure and trade licenses for branches or subsidiaries
Clarification: Shows your corporate footprint and associated risk exposures.
- SLAs with outsourced service providers
Clarification: Confirms third-party arrangements are governed and monitored.
Section 2: Financial & Banking Information
- Audited/unaudited financials for the past two years
Clarification: Reveals financial health and potential risk factors. - AECB credit report
Clarification: Used to assess financial behavior and liabilities. - List of all bank accounts with 12 months of statements
Clarification: Enables review of transactions and banking partners.
Section 3: AML/CFT Policies and Procedures
- AML/CFT Policy and Procedures Manual
Clarification: The backbone of your compliance framework. - Entity-wide risk assessment methodology and results
Clarification: Shows how you identify and address AML risks. - KYC and UBO identification process
Clarification: Ensures proper onboarding and transparency of client ownership.
- PEP identification and handling
Clarification: Demonstrates measures for politically sensitive clients. - Customer risk assessment procedures
Clarification: Describes how you assign and update client risk ratings. - Record-keeping process
Clarification: Confirms compliance with retention and audit requirements.
- TFS implementation process
Clarification: Validates screening against UAE/UN sanctions lists.
Section 4: Compliance Officer Documentation
- CV and job description of compliance officer
Clarification: Ensures the appointed person is qualified and accountable. - Agreements with external consultants (if outsourced)
Clarification: Outsourcing doesn’t absolve accountability, documentation is still required. - Latest internal compliance review report
Clarification: Shows how you self-monitor AML program effectiveness. - Employee training plan and attendance records
Clarification: Confirms that staff are trained and up to date.
- List of goAML reports submitted
Clarification: Demonstrates reporting activity and regulatory engagement.
Section 5: Risk Assessment Files
- Latest risk assessment and methodology
Clarification: Key to your risk-based approach. - Client list with detailed risk classification
Clarification: Proves individualized risk profiles based on geography, service, and transaction data.
Section 6: Customer Due Diligence (CDD/EDD)
- Client list with risk rating, nationality, client type
Clarification: Ensures categorization is in line with AML/CFT obligations. - Client CDD/EDD files
Clarification: Verifies the existence of full documentation. - Supplier list with KYC files
Clarification: Your suppliers must also be subject to due diligence.
- Sample completed KYC forms
Clarification: Evidence that your KYC processes are followed in practice.
Section 7: Politically Exposed Persons (PEPs)
- PEP register and management approvals
Clarification: Required to show oversight of higher-risk clients.
Section 8: Cash Transactions and Virtual Assets
- List of all cash transactions (2 years)
Clarification: Helps assess your exposure to cash-based risks.
- List of virtual asset transactions
Clarification: Important for assessing digital asset risk exposure.
Section 9: Ongoing & Transaction Monitoring
- Documented monitoring process
Clarification: Needed to verify continuous oversight.
- List of red flags used in monitoring
Clarification: Ensures you’re tracking the right indicators.
Section 10: goAML Reporting
- STR/SAR report history
Clarification: Validates that you’ve documented and submitted suspicious transaction/activity reports via the goAML system. - REAR/DPMSR submissions (if applicable)
Clarification: Confirms sector-specific reports were filed, REAR for real estate, DPMSR for gold/precious metals, especially for large cash or virtual asset transactions. - Freezing and name match report list
Clarification: Shows your response to sanctions list hits, including investigations and any asset freezing actions.
Section 11: Record Keeping
- Sample files showing record retention
Clarification: Demonstrates adherence to documentation policies.
Section 12: Targeted Financial Sanctions
- Screening result samples
Clarification: Proves your sanctions checks are functional.
Section 13: Internal Audit
- Latest audit on AML/CFT effectiveness
Clarification: External or internal verification of your controls.
Section 14: AML Training
- Staff and management training list
Clarification: Shows that AML knowledge is being maintained.
- Compliance officer training record
Clarification: Confirms the officer is keeping pace with requirements.
Closing Reminder
Failure to meet these requirements can result in fines from AED 50,000 to 5 million, license suspension, or full operational bans.
InfoAML helps you stay prepared with built-in tools for documentation, reporting, screening, and compliance audits. 👉 Book a free demo today and see how it works in action.
Also Recommended:
If you're a CEO or business owner looking for a leadership-level overview of AML inspections, read our companion article:
👉 AML Compliance Inspections: A CEO’s Guide to Avoiding the Mistakes That Cost Millions