AML Policy in UAE | Custom AML/CFT Compliance Frameworks

In today’s rapidly evolving regulatory landscape, Anti-Money Laundering (AML) policies are no longer optional—they are foundational. An AML policy acts as the internal compass of a company’s compliance posture, outlining how it detects, prevents, and reports suspicious activities related to money laundering, terrorist financing, and financial crime. In the UAE, AML regulations are governed by Federal Decree Law No. (20) of 2018 and enforced through the UAE Central Bank, the Financial Intelligence Unit (FIU), and other supervisory bodies. At Finjuris Global, we craft bespoke AML policies tailored to the nature, risk, and complexity of your business, ensuring compliance with UAE requirements and FATF standards.

A robust AML policy not only protects your business from legal liabilities but also enhances its credibility with banks, regulators, and investors. At Finjuris Global, we believe that compliance should be a business enabler, not a burden. Our AML policy drafting services are designed to integrate seamlessly into your existing operations, helping you stay audit-ready, risk-resilient, and regulator-approved. With Finjuris by your side, you can confidently face inspections, build institutional trust, and scale your operations in full compliance.

Our Services

At Finjuris Global, our AML policy services go far beyond templates. We design, draft, and implement policies that reflect your business activities, customer risk profile, and reporting obligations under UAE law. Whether you’re a startup in crypto, a DNFBP, a fintech company, or a large financial institution, we tailor each policy to cover your onboarding processes, KYC protocols, risk-based approach, escalation procedures, training schedules, and STR/SAR filing guidelines.

At Finjuris Global, our AML Policy offering establishes the backbone of your compliance program, tailored for UAE regulators, financial institutions, VASPs, and DNFBPs:

Comprehensive AML/CFT Policy Drafting

Craft bespoke policy documents covering KYC/CDD, UBO checks, PEPs screening, sanctions, transaction monitoring, internal investigations, and record-keeping in line with CBUAE, DFSA, ADGM, and FATF standards .

Risk-Based Approach & Gap Analysis

Evaluate your business model and transaction streams to identify AML policy gaps, install risk scoring systems, and tailor thresholds based on sectoral risk profiles.

Customer Acceptance & Due Diligence Protocols

Define customer screening levels—simplified, standard, enhanced—ensuring policies for ongoing CDD, source-of-funds tracing, and UBO verification are robust and UAE-compliant.

Transaction Monitoring & Escalation Frameworks

Integrate red-flag indicators, high-risk trends, and threshold logic into AML policy, including STR escalation procedures to FIA/goAML.

Sanctions & Watchlists Management

Embed sanctions lists screening (UN, US, EU, OFAC, UAE) into onboarding and monitoring flows; define hit-generation rules, false positive workflows, and denial protocols.

AML Training Policy Integration

Develop documented training matrices in AML policy covering frequency, audience segmentation (frontline, compliance, senior leadership), and performance tracking .

Independent Compliance Review Provision

Facilitate third-party review clauses within policy to mandate annual or biannual AML framework assessments for continuous improvement.

Policy Governance & Sign-off Controls

Embed review, approval, version tracking, and board-level accountability mechanisms in policy documents for regulatory transparency.

Digital Compliance Tools & Evidence Logging

Align AML policy to support tech-driven implementations—e.g., KYC platforms, transaction surveillance systems, goAML reporting dashboards.

Multi-Jurisdictional Adaptation

Adjust policy frameworks for Free Zones (DIFC, ADGM), mainland UAE, or offshore operations, ensuring legal consistency across jurisdictions.

Our goal is to ensure that your AML framework is not only legally compliant but also practically executable. With Finjuris Global, you get more than documentation, you get a strategic compliance partner. From first draft to ongoing updates, we ensure that your AML policy remains aligned with regulatory changes and business evolution.

Why does it matter?

Having a well-structured AML policy is not just a legal formality; it’s a frontline defense against financial crime. Regulatory authorities in the UAE are stepping up enforcement, with penalties ranging from hefty fines to license cancellations for entities failing to implement adequate AML controls. An AML policy formalizes your internal processes, defines roles and responsibilities, and ensures that everyone from your compliance officer to front-line staff knows how to recognize and report suspicious behavior.

Regulatory Compliance Mandate

UAE regulations mandate written AML/CFT policies covering KYC, monitoring, reporting, governance, and independent review.

Risk Mitigation

A well-structured policy reduces exposure to money laundering, sanctions breaches, fraud, and financing of illicit activities. It also protects your business license and reputation.

Audit Readiness

Regulators—CBUAE, DFSA, FIA, ADGM, expect written policies with version control, documented reviews, and evidence of enforcement, making policy presence critical to passing inspections.

Operational Clarity

AML policy clarifies roles, approvals, escalation workflows, and responsibility matrices—reducing inefficiencies and compliance errors across departments.

Investor & Partner Confidence

Banks, investors, joint ventures, and international firms require evidence of strong AML structures, which starts with a well-drafted policy framework.

Alignment with Global Standards

AML policy consistency with FATF recommendations strengthens the UAE’s position as a financial hub and supports cross-border operational integrity.

Ignoring AML policy requirements places your business at risk of reputational damage, regulatory scrutiny, and financial loss. A sound AML policy can help you safeguard assets, win stakeholder trust, and foster long-term growth. With Finjuris Global’s expertise, you ensure that your business is not only compliant, but also future-ready.

Why Should You Choose Finjuris Global for AML Policy?

Finjuris Global stands out for our multidisciplinary approach to AML compliance. We don’t just write policies, we align them with your operations, digital systems, sector-specific risks, and employee training. Our team includes lawyers, financial analysts, and regulatory specialists who ensure your AML policy meets all UAE and international standards.

Strategic Policy Alignment

Our frameworks begin with operational context—balancing control depth with your business model, jurisdictional needs, and risk appetite.

Full-Spectrum Policy Development

From initial drafting to structuring training modules, compliance sign-offs, and digital system support—we create policies that work in practice.

Cross-Disciplinary Expertise

Our team integrates legal, AML, tax, digital, and governance perspectives to produce policies that endure regulatory change.

Regulator Insight & Liaison

We ensure your policy aligns with regulator expectations and assist in demonstrating design rationale during audits.

Sector-Specific Adaptation

Whether you operate in banking, crypto, real estate, healthcare, or professional services, our policy reflects the unique threats and typologies you face.

Transparent Engagement

Clear deliverables, timelines, and a fixed-fee structure ensure pricing clarity and project accountability.

What sets us apart?

At Finjuris, we believe effective AML policies should be practical, scalable, and defensible. Unlike one-size-fits-all templates, we provide policies tailored to your sector, jurisdiction, and operations. Whether you're a crypto exchange, real estate broker, or consultancy firm, our solutions are built to match your business model and growth strategy.

Compliance-First Digital Frameworks

We design policy to support technology integration, ensuring AML controls are enforced, logged, and auditable.

Proactive Approach

Automate policy updates based on regulatory change (sanctions, typologies, central bank rule releases) rather than reacting post facto.

Audit-Ready Assurance

Each policy includes quality control protocols, evidence checklists, and review logs for regulator-ready status.

Embedded Governance

Policies include clear assignment of AML responsibilities—from board approval, to AML Officer sign-off, to frontline triggers.

Continuous Improvement Built-In

We include review clauses, version control protocols, and gap checklists to keep policy compliant and relevant.

Global Best Practice with UAE Precision

Our frameworks align with international standards like FATF, ACAMS, and Wolfsberg, localized for UAE legal requirements.

We don’t just deliver policies, we deliver peace of mind. From regulatory updates to board-level governance reviews, we stay engaged with your team to ensure your AML policy evolves with your business. Choose Finjuris Global and experience AML policy support that is proactive, precise, and performance-driven.

FAQs

Is an AML policy mandatory in the UAE?

Yes. Both financial institutions and DNFBPs must maintain documented AML/CFT policies governing KYC, monitoring, STR escalation, sanctions, and governance.

How often should AML policies be reviewed?

Minimum: annual. Recommended: when typologies or regulatory frameworks change. Version control and sign-off logs are essential.

Who should approve the policy?

Senior management or board-level executives must formally review and approve policies, with retention of signed version logs.

Can policies be outsourced?

Yes. Drafting assistance by external experts is permitted, but ultimate accountability for policy compliance remains with the regulated entity.

Do I need different policies for UAE Free Zones like DIFC/ADGM?

Minor adjustments may be required to align with local regulators, but the core AML/CFT policy remains largely similar.

How does AML policy tie into goAML STR reporting?

The AML policy outlines procedures for identifying, approving, and submitting STRs via goAML, including timelines and escalation.

Is staff training part of the policy?

Yes. Training frequency, audience segmentation, and refresher scheduling must be documented within the policy itself.

What record-keeping is required?

Policies must define document retention periods—usually 5 years for customer files, STRs, audit logs, and training records.

Can policies be digital?

Yes—electronic policy storage with access logs is acceptable, provided changes and approvals are tracked.

How does an independent audit fit in?

Policy needs to mandate periodic independent AML/CFT compliance reviews to assess policy effectiveness and reporting gaps.

Your AML policy is the cornerstone of your compliance strategy. Partner with Finjuris Global to build robust, regulator-compliant frameworks that enhance governance, deter financial crime, and empower your team.

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POLICIES

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