Ministry of Economy (MoE) inspections are becoming more frequent and data-driven. Inspectors often arrive with a list of "high-risk" transactions they have already identified from your goAML filing history (or lack thereof).
The "First Hour" Document Request
When inspectors arrive, they demand immediate access to specific foundational documents. Delaying these suggests disorganization or negligence.
- Board-Approved AML Policy: Signed and dated by the current management.
- Enterprise Wide Risk Assessment (EWRA): Must be updated within the last 12 months.
- TFS / Sanctions Subscription Proof: Evidence that you receive EOCN emails.
- Training Log: Certificates and attendance sheets for all staff.
- Sample Customer Files (KYC): They will ask for specific high-risk files (e.g., "Show me the file for the AED 5M cash deal on Jan 12th").
Common Failure Points
- No UBO Verification: Having a Trade License copy but no passport copy of the actual human owner.
- Generic Risk Assessment: Using a template that mentions "correspondent banking" when you are a real estate agent.
- Missing Screening Evidence: You screened the customer, but you didn't save the screenshot or report proving it was done before the transaction.
Author: Zeej Strategic Consulting Research Team