Auditors and accountants in the UAE play a critical role in maintaining financial transparency, but this also makes them vulnerable to money laundering (ML) and terrorism financing (TF) risks. Given the nature of their work, compliance with AML/CFT obligations is not just a recommendation, it is a regulatory requirement under UAE law. Failure to adhere to these regulations can lead to severe consequences, including hefty fines, reputational damage, and loss of professional licenses. Non-compliance also exposes firms to legal liabilities and can jeopardize their ability to operate within the financial ecosystem.

Under UAE decree-law No. 20 of 2018 and cabinet decision No. 10 of 2019, auditors and accountants are listed under designated non-financial businesses and professions (DNFBPs) and must fully comply with AML/CFT regulations. Effective AML/CFT compliance is essential to safeguard your firm from risks associated with money laundering and terrorist financing. This requires a systematic approach across multiple dimensions of your business operations and client engagements.

AML/CFT Compliance Requirements and Measures

1. Risk Identification & Assessment

Effective risk management begins with a clear understanding of where vulnerabilities lie within your firm’s operations and client profiles.

• Conduct regular risk assessments and document the results.
• Understand potential exposure to money laundering and terrorist financing risks in your audit and accounting activities.
• Identify risk factors related to client types, transaction nature, geographic locations, and delivery methods.
• Look out for red flags such as complex ownership, unusual transactions, and suspicious asset valuations.
• Stay equipped with the right technology solutions which align with your business AML compliance requirements efficiently to identify, monitor, and mitigate risks.

2. Internal Policies & Controls

Robust internal controls are essential for preventing misuse of services and enhancing compliance with the AML compliance regulations. These controls should be comprehensive, regularly updated, and tailored to the nature and size of your business. Key elements include:

• Clear policies for Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD).
• Procedures for identifying and reporting suspicious activities and transactions.
• Maintain proper records of client identification, transactions, and reports for a minimum period (usually 5 years).
• Defined roles and responsibilities for compliance within the organization.
• Ongoing staff training programs to ensure awareness of AML obligations and red flags.
• Periodic AML risk assessments to identify evolving threats or weak controls.
• Regular internal audits or independent reviews to test the effectiveness of your AML framework.
• Escalation protocols for high-risk clients or unusual findings.
• Whistleblower mechanisms to encourage internal reporting without retaliation.

All controls must align with your risk levels and regulatory expectations, and be reviewed periodically to ensure they remain effective in an evolving risk environment.

3. Customer Due Diligence (CDD)

Understanding who you are dealing with is a fundamental step in preventing financial crime. Weak CDD practices can expose firms to serious AML compliance risks, including:

• Undisclosed links to known financial criminals
• Hidden or indirect connections to Politically Exposed Persons (PEPs)
• Associations with high-risk jurisdictions or suspicious corporate networks

Effective CDD goes beyond document collection, it requires ongoing assessment of client profiles, behavior patterns, and risk indicators.

4. Reporting Suspicious Activity

If you identify any red flags, you are legally required to report them to the UAE Financial Intelligence Unit (FIU) through the goAML portal. Timely and well-documented Suspicious Transaction Reports (STRs) are crucial to protect your business from money laundering and terrorist financing. Common suspicious indicators include:

• Unusually large or rapid movement of funds without a clear economic rationale.
• Transactions inconsistent with the client’s known business or risk profile.
• Frequent small transactions (structuring/smurfing) that appear designed to evade detection or thresholds.
• Payments involving offshore companies, shell entities, or unrelated third parties.
• Concealment of fund sources or complex layering of transactions.
• Clients reluctant to provide required documentation or giving conflicting information.
• Sudden changes in transaction patterns without explanation.
• Even low-value transactions can signal criminal activity if they are part of a broader pattern.

5. Ongoing Monitoring

Ongoing monitoring for accounting and auditing sector is a critical component of an effective AML program. Auditors and accountants must not treat due diligence as a one-time exercise. Risk profiles can evolve, and continuous vigilance is required to detect emerging threats. Key steps include:

• Periodic review of client profiles, especially high-risk clients.
• Re-screening clients against updated sanctions, PEP, and watchlists on a continuous basis.
• Checking for adverse media or negative news involving clients or key personnel.
• Monitoring changes in business ownership, structure, or control.
• Identifying unusual transaction patterns that deviate from expected business activity.
• Verifying that payments originate from legitimate and expected sources.
• Assessing any new geographic exposure or high-risk jurisdictions.

By staying alert to changes and regularly updating risk assessments, professionals can help ensure ongoing compliance and reduce exposure to financial crime.

How FinchSCAN Helps

FinchSCAN is designed for professionals like accountants, auditors, and other DNFBPs, who need a user-friendly and cost-effective solution to meet their AML compliance requirements. Here is how FinchSCAN supports your AML compliance process:

Name Screening: Instantly screen your individual and corporate clients against global and local sanctions Lists, PEP databases, and adverse media.

Ongoing Monitoring: Stay ahead of potential risks with our ongoing monitoring feature to get real-time alerts whenever there are changes in your client’s risk profile or sanctions status.

goAML/Regulatory Reports: FinchSCAN lets you quickly generate and export STRs and SARs in a goAML-ready format. Select the report type, fill in the details, and submit with ease, saving your time and effort.

Multi-language & Transliteration Support: Screen names across multiple languages including Arabic and English, using our advanced transliteration feature for more enhanced matching.

No Setup or Integration Required: FinchSCAN is SaaS-based model, easy to access, and works without complex integrations, saving your hardware and implementation costs.

Pay-as-You-Go Model: Only pay for what you use, ideal for firms with fewer screening requirements.

🔗 Read more about our features here.

Whether you are onboarding a new client, reviewing existing ones, or responding to a suspicious activity or transaction, FinchSCAN gives you the tools to enhance your AML compliance without slowing down your business or your growth.