AML Compliance in the UAE: Tips to Prepare Flawless MLRO Reports

Financial institutions and DNFBPS, VASPs service providers in the UAE are struggling with AML compliance, especially in providing adequate MLRO reports. All too often, companies find themselves in situations where a lack of experience or ambiguous internal procedures contributes to gaps in AML defences.

The solution is JCA (Jitendra Chartered Accountants), helping you know precisely what is expected in an MLRO report, teaching you detailed reporting methods, and providing best-practice guidance. With the assistance of our AML consultants in the UAE, any organisation can achieve compliance and improve overall AML processes.

What is an MLRO Report?

An MLRO report is the internal report prepared by the Money Laundering Reporting Officer (or equivalent officer) of a financial institution or designated non-financial business or profession (DNFBP) or VASPs in the UAE. While older rules such as Cabinet Decision No. 10 of 2019 set out guidance, under the new Federal Decree‑Law No. 10 of 2025 institutions should ensure that their reporting aligns with the risk-based obligations, submission requirements, and supervisory authority guidelines under the new regime.

Note that the statute does not itself define a universal standard format for an MLRO Report; instead institutions must align with the Supervisory Authority’s regulations and tailor reports in line with the risk-based approach required by the New AML Law.

The report by the MLRO reviews the organisation’s internal controls and level of adherence to laws on AML-CFT, identifying those areas that need attention. The report shows the commitment of the company to combat money laundering and financing of terrorism, while it helps the management update policies and procedures.

Key Components of an MLRO Report

Writing an effective MLRO report requires the inclusion of certain elements, which is done effectively by our expert AML consultants in Dubai:

• Executive Summary: Highlight significant compliance gaps and steps taken to bridge those gaps.
• Suspicious Activity Reports: Include the number of reports filed internally, assess the quality, and mention whether further training is needed by staff.
• Client Screening: Identify any rejected clients due to incomplete or insufficient information. Include any external SARs filed.
• Training Records: AML-CFT training programs for employees are documented, including certificates, assessment results, and knowledge gaps identified.
• Employee Awareness: Evaluate staff knowledge about their contributions to combating money laundering and terrorism financing.
• Resource Needs: Indicate whether any additional resources will be necessary to strengthen AML compliance.
• Customer Due Diligence Review: Perform sample checks to ensure that the client files are complete and risk ratings are up-to-date.
• Policy Evaluation: Verify whether AML-CFT policies, procedures, and risk assessments remain relevant and current.

Incorporating these items (above are not exhaustive but only taken as an example) will help the report meet good-practice expectations and support management and the supervisory authority in assessing the institution’s AML-CFT controls. Under the New AML Law’s enhanced regime, institutions must ensure their report reflects the risk-based approach, virtual asset exposures, sanctions compliance and beneficial-ownership transparency.

The Role of the MLRO in the UAE

The MLRO shall implement the risk-based approach and ensure that systems are in compliance with the AML-CFT regulations. Key responsibilities include:

• Overseeing internal AML-CFT controls.
• Update the risk assessments for the organisation.
• Receiving internal SARs and determining whether to report them to authorities.
• Advising management on policy updates and resources.
• Training and awareness of AML responsibilities among staff.

Under the New AML Law, the MLRO (or equivalent) should also ensure:

• That the institution considers the expanded scope of predicate offences (including tax evasion, proliferation financing) as defined in Article 1 of the law.
• That systems cover virtual assets, digital systems and encryption technologies as defined in the law.
• That senior management (and not just the MLRO) are aware that liability can attach personally under the New AML Law for failure to implement appropriate controls.
• That executive regulations and supervisory authority expectations (which may vary by industry) are considered.

A well-prepared MLRO report by JCA’s expert AML consultants in the UAE serves to illustrate both the officer’s understanding of these responsibilities and the firm’s commitment to regulatory compliance.

Lessons from Compliance Failures

Cases involving persons like that of David Brian Price highlight the outcome of poor MLRO oversight: severe penalties, prohibition orders, and withdrawal of approvals for failure to conduct business with integrity and failure to manage risk. On a related note, the MLRO of Sonali Bank was fined for not establishing appropriate AML controls, failing to provide proper training, and disregarding operational gaps.

These examples also underline how diligence, integrity, and proper reporting play a significant role. MLROs have to ensure that every SAR is reviewed, training is effective, and that internal policies are current; failure to do so can impact the firm’s reputation and bring about significant financial and legal effects.

Strategies for Preparing Flawless MLRO Reports

Some of the ways businesses can avoid penalties and enhance their AML compliance include:

• Ongoing Training: The requirement is to keep staff and senior management informed and trained in AML-CFT-and-proliferation financing obligations.
• Quality Control: Systematically review internal reports and CDD files for deficiencies.
• Resource Planning: The organisation should provide adequate staff and resources to deal with AML compliance.

How can Jitendra Chartered Accountants (JCA) help?

MLRO reports represent an organisation’s commitment to preventing financial crimes, rather than being simply a formality. By proper identification of the requirements, proper maintenance of records, and utilisation of experience, JCA’s MLROs and AML experts in the UAE prepare precise, compliant, and reliable reports. This kind of structured reporting reduces not only the risk of penalties but also reinforces the overall AML framework of your organisation for long-term compliance and operational integrity.