For licensees with a framework or review due
A licensee with an AML framework or review due
The short answer
A licensee with an AML/CFT framework to build, or a review, audit or inspection due, gets the framework reviewed against the regulator's rulebook and the federal law, with the gaps closed in order of risk. Risk assessment, policies, customer due diligence, monitoring, reporting, training and the appointed officers are each read and evidenced as the reviewer will ask for them.
An AML framework is judged on two things: whether it fits the business's actual risks, and whether it can be shown to work. The first is the business risk assessment — customers, products, geographies, channels — and the policies that follow from it; the second is the evidence: due-diligence files, monitoring alerts and their disposition, suspicious-transaction reports, training records, the compliance officer's reports to the board. A framework that exists on paper but cannot be evidenced fails the review as surely as one that does not exist.
Reviews arrive on a schedule — the regulator's inspection cycle, the rulebook's periodic independent review, an auditor's request, a bank's or a counterparty's onboarding — and the businesses that pass are the ones that reviewed themselves first. The work here is that review: honest, ordered by risk, and finished before the regulator's letter rather than after it.
At a glance
- Indicative cost
- Regulator fees, where any, are the regulator's; the VelaroZone service fee for the gap review and the remediation is fixed against a defined scope, with ongoing support monthly, in your engagement letter.
- Timing
- The gap review in weeks; remediation ordered by risk; the review, audit or inspection supported on its own schedule.
- What's included
- A gap review against the rulebook and the law
- Risk assessment, policies and processes built or corrected
- The evidence pack a reviewer asks for
This is for you if
- You are licensed by VARA, a financial free-zone regulator, the Central Bank or another authority that requires an AML framework.
- Your framework has to be built for a licence application or a new activity.
- An independent review, an audit or a regulator's inspection is due, or overdue.
- A bank or a counterparty has asked to see your AML controls before onboarding you.
This may not be the right route if
- You want a framework written to be filed and forgotten.
- You want a legal opinion on the law; that comes from a licensed law firm, which we coordinate.
- You expect the regulator's finding to be promised.
At a glance
- Indicative cost
- Regulator fees, where any, are the regulator's; the VelaroZone service fee for the gap review and the remediation is fixed against a defined scope, with ongoing support monthly, in your engagement letter.
- Timing
- The gap review in weeks; remediation ordered by risk; the review, audit or inspection supported on its own schedule.
- What's included
- A gap review against the rulebook and the law
- Risk assessment, policies and processes built or corrected
- The evidence pack a reviewer asks for
What this service includes
- A gap review of the framework against the regulator's rulebook and the federal AML law, ordered by risk.
- The business risk assessment written or refreshed; policies and procedures drafted or corrected.
- Customer due-diligence, monitoring and reporting processes designed to produce evidence as they run.
- Training delivered and recorded; the compliance officer's reporting to the board set up.
- The evidence pack prepared for the independent review, the auditor or the regulator.
What it does not include
- Legal opinions on the law or the rulebook, which come from a licensed law firm.
- Any assurance of the regulator's or a reviewer's finding.
- Acting as a shield: a compliance officer reports what the rules require, including to the regulator.
Process
How the work is sequenced
Each stage has its own dependencies — activity approvals, document legalisation, authority processing, and bank review — and we report progress against them rather than against one overall date.
- 01
Gap review
The framework read against the rulebook and the law; findings ordered by risk.
- 02
Remediate
Risk assessment, policies, processes and governance built or corrected.
- 03
Evidence
Files, registers and records assembled as a reviewer will ask for them.
Need the officer as well as the framework? The fractional-roles page fills the role.
Prefer to start in writing? Send the details through the contact form.
Start with a structure assessment
In an initial consultation you receive a plain-language decision summary, a document-preparation list, and the next actions for your situation. Current figures are confirmed within your adviser-reviewed route comparison.
What a reviewer tests
The framework, element by element
A review walks these in order and asks for the evidence behind each.
Elements of an AML/CFT framework and the evidence a reviewer expects for each.
Business risk assessment
- What it must do
- Identify and rate the risks the business actually runs
- Evidence
- The assessment, its methodology and its approval
Policies and procedures
- What it must do
- Say what staff do about each risk
- Evidence
- Documents, versions, approvals, staff acknowledgement
Customer due diligence
- What it must do
- Identify, verify and risk-rate every customer, with enhanced measures where required
- Evidence
- Sampled customer files
Monitoring
- What it must do
- Detect and review unusual activity
- Evidence
- Alerts, their review and their disposition
Reporting
- What it must do
- Report suspicious activity to the authority as the law requires
- Evidence
- The reporting officer's register and filings
Governance and training
- What it must do
- An accountable officer, board oversight, trained staff
- Evidence
- Appointments, board reports, training records
| Element | What it must do | Evidence |
|---|---|---|
| Business risk assessment | Identify and rate the risks the business actually runs | The assessment, its methodology and its approval |
| Policies and procedures | Say what staff do about each risk | Documents, versions, approvals, staff acknowledgement |
| Customer due diligence | Identify, verify and risk-rate every customer, with enhanced measures where required | Sampled customer files |
| Monitoring | Detect and review unusual activity | Alerts, their review and their disposition |
| Reporting | Report suspicious activity to the authority as the law requires | The reporting officer's register and filings |
| Governance and training | An accountable officer, board oversight, trained staff | Appointments, board reports, training records |
The service
Regulatory consulting and fractional roles
The service page sets out VARA licensing advisory, AML/CFT frameworks and the fractional roles a regulated business must fill.
See the consulting service
Every route is planned against how the business will actually operate in the UAE.
After the licence
What you may also need
The four services most founders in this situation ask about next, each on its own page.
Visas & PRO services
Residence visas for owners, staff and family, Emirates ID and medicals, and the PRO work that keeps a licence and its people in good standing. Eligibility and approval stay with the authority.
→UAE bank account setup
A bank-ready file and an introduction to the bank whose appetite matches your profile. Approval and timing stay with the bank.
→Accounting & bookkeeping
Monthly bookkeeping, VAT and corporate-tax filings, and year-end accounts, with statutory audit referred to a registered auditor.
→Legal services
Contracts, corporate documents, disputes and regulatory matters, advised by licensed law firms from our network.
→
Questions
Frequently asked
- How often must the framework be reviewed?
- As the regulator's rulebook and the law require — typically an independent review on a set cycle, a refreshed risk assessment when the business changes, and the regulator's own inspections on its schedule. We diarise all three.
- Can the same person be compliance officer and reporting officer?
- Some regulators allow it for smaller firms and some require separate appointments; both roles are subject to the regulator's approval of the person. The fractional-roles page covers filling them.
- What does a regulator's inspection look like?
- A request for documents and files, interviews with the officers and sometimes staff, sampled customer files and monitoring records, and a report with findings and deadlines. The evidence pack is built so the request is answered from the file, not reconstructed.
- Our bank has asked for our AML policy. Is that normal?
- Yes, for licensed and higher-risk businesses; the bank has its own obligation to understand your controls. A framework that can be shown is what keeps the account open.
- What does it cost?
- A gap review and remediation are quoted as a fixed VelaroZone service fee against a defined scope; ongoing support is monthly. Both are itemised in your engagement letter.
Sources
- UAE AML/CFT framework guidance
- Virtual Assets Regulatory Authority (VARA)
- Central Bank of the UAE — the UAE banking and payments regulator
Regulations, fees, and eligibility can change. Every regulatory statement is re-checked before publication and dated above.
Legal notes and scope
Velarozone provides setup and operational-readiness coordination. This page is general information, not legal, tax, immigration, or banking advice.
This page is general information about UAE business setup, not legal, tax, immigration, or banking advice. Rules, fees, permitted activities, and bank policies can change. Final eligibility depends on your facts and the applicable rules at the time of application.
Regulatory outcomes are decided by the regulator; nothing here asserts a finding, a licence category or a timeline the regulator has not published or decided. Legal opinions come from a licensed law firm under its own engagement.