Proving AML Compliance to Supervisors: UK, India and UAE
Screening and monitoring tools show what happened. Supervisors and auditors also ask you to prove that your policies, officers, reviews and evidence were in place. This guide shows how those obligations map to controls in three regimes.
What an AML audit asks for
Across all three regimes the same questions come up. Firms usually fail on the evidence, not on the tooling:
- A written, approved AML policy and a named compliance or reporting officer.
- A documented risk assessment of customers, products, countries and channels, reviewed on a schedule.
- Customer due diligence and beneficial ownership records, with enhanced checks for higher risk.
- Staff training records and proof of who completed them.
- Record keeping for the period the law sets, and a trail of reports made and decisions taken.
- Proof that sanctions and screening checks ran, and that alerts were reviewed.
Three regimes, as controls
United Kingdom
81 FRAMEWORQ controlsLaw: Money Laundering Regulations 2017 (as amended, including SI 2026/621 made on 9 June 2026), the Proceeds of Crime Act 2002 and the Terrorism Act 2000.
Typically applies to: Firms supervised by the FCA, HMRC or a professional body.
Control areas:
- Scope and applicability
- Risk assessment
- Policies, controls and training
- Customer due diligence
- Enhanced due diligence and politically exposed persons
- Simplified due diligence
- Reliance, records and data protection
- Beneficial ownership information
- Supervisors and registration
- Transfers of funds and cryptoasset transfers
- Offences and liability
- Disclosure and reporting
- Sanctions reporting
India
78 FRAMEWORQ controlsLaw: Prevention of Money-laundering Act 2002, the Maintenance of Records Rules 2005 and the directions of the sector regulator (for example RBI or SEBI).
Typically applies to: Reporting entities under the PMLA, reporting to FIU-IND.
Control areas:
- Scope and reporting-entity status
- Governance and officers
- Risk assessment
- Policies, controls and monitoring
- Client due diligence and KYC
- Enhanced due diligence
- Beneficial ownership and CKYCR
- Record keeping and retention
- Reporting to FIU-IND
- Sanctions and proliferation financing
- Sector regulator obligations
United Arab Emirates
71 FRAMEWORQ controlsLaw: Federal Decree-Law No. 10 of 2025, which replaced Federal Decree-Law No. 20 of 2018 and took effect on 14 October 2025, with its Executive Regulations.
Typically applies to: Financial institutions, virtual asset service providers and designated non-financial businesses.
Control areas:
- Scope and licensing
- Risk assessment and mitigation
- Governance and compliance function
- Customer due diligence
- Politically exposed persons and high-risk countries
- Suspicious transaction reporting
- Targeted financial sanctions and freezing
- Record keeping
- Financial institution obligations
- Virtual asset service providers
- Transparency and beneficial ownership
- Non-profit organisations
Control counts are the sizes of FRAMEWORQ's own control sets, not counts of statutory clauses. Check the current text of each law, and the commencement dates of recent changes, with a qualified lawyer.
Where readiness software fits, and where it does not
| Job | Done by | FRAMEWORQ |
|---|---|---|
| Sanctions, PEP and adverse media screening | Screening and data providers | No. Tracks the control and keeps the evidence that checks ran. |
| Transaction monitoring and alerts | Monitoring platforms | No. Tracks alert review and sign-off evidence. |
| Filing reports with FIU-IND, the UK NCA or the UAE FIU | Your compliance officer, through the regulator's own channel | No. Records that reports were made and reviewed. |
| Policies, owners, risk assessment, training, review calendar | Spreadsheets, documents and email today | Yes. Controls with owners, due dates and evidence in one place. |
| Showing a supervisor or auditor that it all happened | A manual evidence hunt before each inspection | Yes. A read-only auditor view of controls and evidence. |
Frequently Asked Questions
Does FRAMEWORQ screen customers or monitor transactions?
Why would a firm with a transaction monitoring tool still need audit readiness?
Are the control counts the number of clauses in the law?
Is this legal advice?
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