Audit-Ready by Design: Turning Policy into Evidence in the UAE

In the UAE, having policies isn’t enough.

Regulators and auditors now test operational effectiveness and evidence trails under the UAE AML law and its Implementing Regulations, and inside the DIFC (Dubai International Financial Centre) under the regulator's DFSA rulebooks. If you can’t produce verifiable artefacts quickly (logs, registers, approvals, testing results), you don’t have a control environment; you have a document folder.

Why evidence is the new battleground

• Statutory duties: Federal Decree-Law 20/2018 and Cabinet Decision 10/2019 require risk-based AML/CFT controls, proper recordkeeping, and cooperation with competent authorities, expect to show what you did, not just state what you would do.

• Named accountability: DFSA’s AML module assigns explicit MLRO responsibilities (escalation, reporting, oversight), which must be demonstrated through working papers, MI and board reporting.

• Raised expectations: Since 2020, UAE authorities have tightened supervision and follow-ups; retrieval times and the quality of evidence files are increasingly scrutinised.

Where programs typically fail

1. Policy–practice gaps: EDD is “required” on paper, but workflows permit onboarding before risk scoring is final.

2. No evidence map: Teams do controls, but don’t output immutable artefacts (e.g., case notes, screening exports, exception memos) with timestamps and ownership.

3. Undefined cadence: No monthly MI, quarterly testing, or annual independent effectiveness review; nothing to show trend lines or remediation cycles.

4. Change management drift: New products, geographies, or vendors aren’t reflected in the Risk Assessment, control library, or training.

What “good” looks like

• Risk taxonomy & appetite: Risks by product, client type, geography; written appetite statements with thresholds (when to escalate, when to decline).

• Control library: For each risk, preventive/detective control, owner, frequency, sampling approach, and evidence type with storage path.

• Assurance calendar: Monthly MI (alerts, EDD files, exceptions), quarterly sample testing with findings and closures, and an independent annual look-back.

• Board discipline: Minutes that capture challenge, decisions, and action closure proof (attachments referenced, not just “noted”).

• Retrievability KPI: Target <48h to produce a full client file (risk score, screening logs, approvals, transaction flags, and closure notes).

Day-0 artefact checklist (auditors will ask for these):

Risk Assessment, Risk Appetite, Control Library, SOP pack, Investigations playbook, Incident/Breach/Conflicts/G&H registers, Training matrix & completion logs, MI pack with trend analysis, and a Q&A tracker linking regulator queries to documentary proof. (Within DIFC, align to DFSA GEN 5 on systems & controls and AML module requirements.)

How Marensa helps

90-day Audit-Ready Program

• Design (Weeks 1–3): Gap-assessment vs. UAE law & DFSA AML; refresh Risk Assessment & Appetite.

• Build (Weeks 4–8): Control library, SOPs, evidence map, registers; MI & dashboard structure; document retention and access rights.

• Assure (Weeks 9–12): Dry-run audit on real files; defect log with owners/dates; board pack for sign-off.Deliverables: Complete artefact set plus an Evidence Retrieval Playbook (who pulls what, from where, in what format).Outcome: Evidence you can produce on demand—aligned with UAE AML law, Cabinet Decision 10/2019, and DFSA AML/GEN systems-and-controls expectations.