Bespoke AML/CFT Policies & Procedures.
Custom internal control manuals, customer due diligence (CDD) procedures, and business risk assessments. Tailored to UAE Ministry of Economy and Central Bank standards.
Bespoke Manuals Tailored to Your Specific Risk Profile
In the UAE, Cabinet Decision No. 10 of 2019 requires all Designated Non-Financial Businesses and Professions (DNFBPs) to establish, document, and maintain internal Policies, Controls, and Procedures (PCPs) to mitigate money laundering risks.
Generic templates are frequently rejected during inspections by the Ministry of Economy or Central Bank. A compliant compliance manual must reflect the specific nature of your business operations, client segments, geographical exposures, and distribution channels.
“Your manual must detail exactly how your organization screens sanctions lists, verifies beneficial owners, and detects suspicious transactions.”
Standard Modules of an AML/CFT Manual
An overview of the core compliance frameworks that form the foundation of a robust internal policy manual.
Customer Due Diligence (CDD)
Core Compliance Module
Standard protocols for identifying clients, verifying Ultimate Beneficial Owners (UBO), and screening Politically Exposed Persons (PEP) prior to engagement.
Notice: These modules represent the basic legal structure required under UAE AML regulations. Delphi coordinates with your compliance officer to document how these steps are operationalized inside your business workflow.
Custom Documentation Deliverables
We draft bespoke manuals tailored to your license activity, matching the standards required by UAE supervisors.
Business Risk Assessment (BRA)
Documenting the inherent risk levels of your customers, services, geographic reach, and transactions, followed by mitigation controls.
Customer Due Diligence (CDD)
Bespoke KYC procedures detailing how customer documents are collected, verified, and updated, including beneficial owner (UBO) structures.
Sanctions Screening Policies
Setting up internal rules for screening clients against local UAE terrorist databases and the UN Consolidated Lists prior to transactions.
Record-Keeping Standards
Procedures mapping how client documents, risk profiles, and transaction records are archived for the legally required 5-year period.
How We Build Your Compliance Manual
A three-step documentation process built around analyzing, customizing, and handing over compliant manuals.
Business Analysis
Reviewing your trade license activities, target customer profiles, transaction sizes, and geographic flows to map your specific risk profile.
Bespoke Drafting
Compiling custom Customer Due Diligence (CDD), Enhanced Due Diligence (EDD), and transaction monitoring guidelines for your manual.
MLRO Handover & Coaching
Delivering the finalized compliance manual and conducting training sessions with your appointed AML Compliance Officer (MLRO).
Frequently Asked Questions
Build an Unshakeable
Compliance Framework.
Don\'t rely on generic templates. Settle tailored, audit-ready AML/CFT policy manuals that protect your trade license and pass supervisor inspections.