How to Conduct an Internal AML Audit in Your UAE Business

Introduction

Think your AML files are in order? Don’t wait for the Ministry of Economy to find out the hard way.

Internal AML audits are no longer optional, they’re essential. Whether you're a real estate brokerage, gold trader, law firm, or corporate service provider, proactively checking your own compliance systems is the smartest way to avoid penalties, reputation damage, or even license suspension.

Here’s how to conduct an internal AML audit that regulators will respect, without the stress, and without the guesswork.

Why Conduct an Internal AML Audit?

• Prove your compliance before the regulators check it
• Identify weaknesses in your AML systems
• Avoid last-minute scrambling during inspections
• Build confidence with senior management and partners
• Reduce the risk of administrative fines under Cabinet Decision No. (71) of 2024

What Inspectors Expect, And Why Internal Audits Help

AML inspectors don’t just check your policies. They look at:

• Evidence of implementation
• Consistency across files
• Documentation and training logs
• Whether staff know their compliance responsibilities
• Systems for monitoring and reporting

An internal audit helps you walk in the inspector’s shoes and fix issues before they appear on a violation list.

Step-by-Step Internal AML Audit Process

1. Review Your AML Policy and Risk Assessment

• Is your AML/CFT policy up to date?
• Does it reflect your actual business operations and risk exposure?
• Has your entity-wide risk assessment been reviewed in the last 12 months?

Tip: Check if your policy mentions current UAE laws like Cabinet Resolution No. (10) of 2019 and Decision No. (74) of 2020.

2. Inspect Your Customer Due Diligence (CDD/EDD) Files

• Are all KYC forms complete and signed?
• Is the source of funds documented where required?
• Are high-risk clients identified and supported with EDD?
• Are PEPs flagged and assessed properly?

Tip: Pick a sample of low, medium, and high-risk clients to review across departments.

3. Validate Your Sanctions and PEP Screening

• Are customers screened at onboarding and on a regular basis?
• Are screening results documented (including “no match” outcomes)?
• Are you using updated lists for UAE/UN sanctions and PEPs?

Tip: Check how name variations are handled, especially Arabic and English name mismatches.

4. Assess goAML Reporting and Suspicious Transaction Handling

• Do you have a log of STR/SAR reports?
• Are reports submitted on time and with the correct format?
• Is there an internal review process before submission?

Tip: Inspect your goAML correspondence log, including any responses or queries.

5. Evaluate AML Training and Staff Awareness

• Who has received AML training? When?
• Are there training attendance logs or certificates?
• Was the MLRO trained and is documentation available?

Tip: Interview staff to see if they can explain basic red flags and reporting procedures.

6. Check Record-Keeping and Retention Practices

• Are files retained for 5 years as required?
• Are digital records secure and accessible?
• Are you keeping logs of communications, transactions, and decisions?

Tip: Try retrieving a sample file from 3 years ago, how long did it take?

7. Review Your Internal Monitoring & Audit Logs

• Are you documenting your internal AML reviews?
• Have you conducted any previous audits or gap assessments?
• Are red flags being logged and escalated appropriately?

Tip: Lack of internal reviews is a red flag in itself.

Common Issues Found in Internal AML Audits

• Outdated AML policies
• Missing CDD files or incomplete KYC forms
• No documentation of PEP screening
• STRs not being submitted for suspicious transactions
• No audit trail of decisions or red flag handling
• Staff unaware of their AML duties

Don’t wait for the inspector to find these. Fix them now.

What to Do After the Internal Audit

• Prepare a summary report with all findings
• Assign responsibilities to address gaps
• Update your policies or training plans if needed
• Schedule the next internal audit (annually or biannually)

Treat the internal audit like a health check, not a punishment. It keeps your business safe.

Bonus: How InfoAML Helps You Simplify Internal AML Audits

If you're using InfoAML, your internal audit process becomes dramatically easier. Here’s how:

Centralized AML Documentation

All your CDD files, STR logs, risk assessments, and policies are in one secure place,  accessible anytime.

Sanctions & PEP Screening Audit Trail

See screening results with full match history and explanations, across both Arabic and English names.

goAML Reporting Archive

Easily track what was submitted, when, and by whom, with downloadable logs for inspection purposes.

Documented Risk Ratings and Red Flags

Your internal risk scoring system is traceable, from client onboarding to EDD decisions.

Training Records at Your Fingertips

Store training logs and certificates inside the Document Management module, no more chasing folders before an inspection.

With InfoAML, internal audits aren’t a fire drill, they’re a checklist, and most of it is already done.

Final Reminder: Inspect Yourself Before They Inspect You

Internal AML audits aren’t a burden, they’re your shield. They help you stay in control, stay compliant, and stay off the penalty list.

👉 Book a Free Demo

Let InfoAML show you how to audit your compliance the smart way, before someone else does it for you.