UAE supervisors — the Central Bank (CBUAE), the DFSA in the DIFC and the FSRA in ADGM — expect a risk-based AML/CFT program that is documented and consistently executed, with timely goAML reporting to the UAE FIU. Following the country's FATF grey-list period, examination scrutiny has intensified. Finaxis delivers audit-ready KYC and customer due diligence operations — CDD, ultimate beneficial ownership, sanctions screening and enhanced due diligence — built to withstand examination.
Already trusted by 9 international financial organizations — including Stellantis, Generali and Ayvens.
Fiat ChryslerGeneraliAyvensALD AutomotiveLeasePlanVesting FinanceStellantisBMW Financial ServicesING Lease
The UAE AML/CFT framework
Customer due diligence in the UAE is governed by Federal Decree-Law No. 20 of 2018 on Anti-Money Laundering and Counter-Terrorism Financing and its implementing regulation (Cabinet Decision No. 10 of 2019), overlaid by the rulebooks of the relevant supervisor. A financial institution in the DIFC answers to the DFSA; one in ADGM to the FSRA; and onshore institutions to the CBUAE. The underlying obligations are consistent and risk-based, and an examiner tests them against your actual files, not just your policy.
Customer identification and verification
Establishing and verifying the identity of each customer — for individuals via Emirates ID and passport, for legal persons via trade licence and constitutional documents — with documented procedures for verification and for handling discrepancies.
Ultimate Beneficial Ownership (UBO)
Identifying and verifying the ultimate beneficial owner of legal-person customers in line with Cabinet Decision No. 58 of 2020 on UBO procedures — typically the individual owning or controlling 25% or more — and keeping the register current.
Understanding the business relationship
Developing a customer risk profile — the expected purpose, activity and transaction behaviour — that forms the baseline against which unusual activity is later assessed.
Ongoing monitoring and reporting
Continuous monitoring to detect suspicious activity, keep customer information current, and file Suspicious Transaction and Suspicious Activity Reports through the UAE FIU's goAML platform within the required timeframes.
Sanctions screening — UN, local lists and a strict standard
UAE entities must screen customers and counterparties against the UN Security Council Consolidated List and the UAE Local Terrorist List, with the Executive Office for Control & Non-Proliferation expecting prompt freezing action on true matches. Screening applies at onboarding and on an ongoing basis, with documented procedures for resolving potential matches and escalating confirmed hits.
An automated match is a signal, not a conclusion. Finaxis applies experienced analyst review to clear false positives efficiently and to document the rationale behind every confirmed-match decision — the record a supervisor or auditor will ask to see.
Where a generic KYC process fails an exam
Many programs rely on a standard questionnaire, an automated identity check and a signed declaration. That works for low-risk customers in a stable environment — but it is thin for most commercial relationships and does not meet enhanced due diligence expectations.
Why template KYC breaks down
A generic approach lacks sector-specific risk awareness. The risk factors relevant to an auto or equipment lender financing business customers differ fundamentally from a payments firm or a DNFBP. Templates produce files that look complete but are substantively thin — and examiners read substance, not checkboxes.
Generic tooling is also poorly equipped for the complex, cross-border ownership common in the region: free-zone entities, offshore holdings, layered structures and beneficial owners across multiple jurisdictions. Precisely the structures that surface in trade finance and leasing.
What examination-ready KYC looks like
Quality KYC begins with a risk-based decision on the depth of review — substantiated and documented. The specialist establishes not only who the customer is, but the economic purpose of the relationship, source of funds and wealth where relevant, and the activity that can reasonably be expected. The end product is a file that holds up under examination: structured, reproducible, with a clear decision rationale.
Enhanced Due Diligence (EDD) and PEP screening
EDD applies whenever a customer or relationship presents elevated risk: foreign and domestic PEPs and their close associates, customers connected to higher-risk jurisdictions, cash-intensive businesses, or relationships with no clear lawful purpose. EDD means deeper investigation — verifying source of wealth and funds, consulting additional sources (corporate and free-zone registries, court records, adverse media), setting an enhanced monitoring profile, and obtaining documented senior approval to open or continue the relationship.
Where activity warrants it, our documentation is structured to feed your goAML reporting decisions cleanly — so the MLRO has a complete, defensible record to act on. Finaxis operates as an extension of your program, under your MLRO's oversight; the accountability and reporting decisions remain yours.
Working with Finaxis — examination-ready from day one
Finaxis delivers KYC and CDD as a managed service or as embedded specialists inside your team. Both models produce examination-ready work immediately — no learning curve at the expense of your files.
Our documentation standard
Every file contains: a documented risk rating with rationale, a complete identity-verification record, UBO identification and verification with source attribution, a documented purpose-and-nature profile, and for EDD a full account of the additional investigation, sources consulted, and the approval note.
This protects your institution in the event of a complaint, an examination, or an internal audit — and shortens the time your compliance team spends on remediation. An audit-ready end product is the standard, not an add-on.
Integration and data handling
We work within your existing KYC platform, CRM or document management system — no platform migration required. All work is performed under a written confidentiality and data processing agreement, with role-based access, consistent with your data-protection obligations (including DIFC and ADGM data-protection regimes where applicable).
Frequently asked questions about outsourcing AML and KYC in the UAE
Can a third party perform AML and KYC work for us in the UAE?
Yes. UAE regulations permit reliance on and outsourcing to third parties for CDD functions, but the responsibility and accountability remain with your institution and your MLRO. Finaxis operates under your program and oversight, with full documentation so you retain control and examiner-ready records.
Do you work to DFSA, ADGM and CBUAE expectations?
Yes. The core CDD obligations are consistent across the onshore CBUAE regime and the DIFC (DFSA) and ADGM (FSRA) free-zone rulebooks; we align the documentation and depth to the supervisor relevant to your licence.
How do you handle UBO and sanctions screening?
We identify and verify ultimate beneficial owners per Cabinet Decision No. 58 of 2020, and screen against the UN Consolidated List and the UAE Local Terrorist List at onboarding and on an ongoing basis — clearing false positives with documented analyst review and escalating confirmed matches for prompt action.
What does outsourcing cost?
Depending on volume, risk category and required depth, we work on a per-file, retainer or project basis. Transparent rates are set out in the engagement proposal.
Where is Finaxis based, and can you serve UAE institutions?
Finaxis is based in Amsterdam and works with financial organizations internationally. For UAE engagements we operate to UAE regulatory expectations — Federal Decree-Law No. 20 of 2018, CBUAE/DFSA/ADGM rules and goAML reporting — as an extension of your compliance program.