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AML Agreed Upon Procedures (AUP)
Specialized AML AUP reviews designed for Exchange Houses, Financial Institutions, and DNFBPs. Our experts perform focused testing and verification of controls, ensuring your AML framework meets regulatory expectations and industry best practices.
Who We’ve Worked With
Our Services
Comprehensive Advisory Framework
An Agreed-Upon Procedures (AUP) engagement involves performing specific compliance checks defined by the client, without providing an audit opinion. Under Chapter 16.31 of the Central Bank’s regulations, IMC Group conducts annual AUP reviews on AML/CFT functions for Exchange Houses. The findings are reported to the Board and submitted to regulatory authorities within four months of the financial year’s close, ensuring transparency and compliance with all AML/CFT requirements.
Scope of AML AUP Audit
The AML AUP Audit covers a detailed review of your organization’s compliance framework, risk assessments, and AML/CFT policies. It examines the roles of compliance officers, internal audits, along with KYC procedures and transaction monitoring systems. The audit also assesses sanctions screening, typology reviews, PEP checks, and record-keeping practices to ensure complete regulatory alignment and operational integrity.
Deliverables & Timelines
Successful AUP engagements depend on structured planning and timely execution. Open communication helps set clear expectations, milestones, and resource allocation. For exchange houses, these reviews strengthen AML/CFT frameworks, uphold financial system integrity, and reduce exposure to illicit activities through thorough assessments and effective corrective measures.
How can advisory firms assist in the AML AUP process?
Many companies face uncertainty about which AML controls need attention or how to match regulator expectations. Advisory firms step in by setting clear review procedures, performing independent checks on records, and pointing out control gaps that may lead to compliance issues. They also help organize supporting documents, strengthen reporting practices, and guide management in addressing findings before regulatory inspections.
Why Choose IMC for AML Agreed Upon Procedures (AUP)?
Industry-Specific Expertise
IMC’s compliance specialists have deep experience working with Exchange Houses, Financial Institutions, and DNFBPs, ensuring every AUP engagement aligns with sector-specific regulatory expectations.
Structured Engagement Process
Our methodical approach emphasizes planning, milestones, and transparent communication, helping clients stay on track and meet regulatory deadlines efficiently.
Regulatory Alignment
We conduct AML AUPs in accordance with UAE Central Bank and FATF standards, ensuring that all findings and recommendations support full compliance readiness.
Industry-Specific Expertise
IMC’s compliance specialists have deep experience working with Exchange Houses, Financial Institutions, and DNFBPs, ensuring every AUP engagement aligns with sector-specific regulatory expectations.
Structured Engagement Process
Our methodical approach emphasizes planning, milestones, and transparent communication, helping clients stay on track and meet regulatory deadlines efficiently.
Regulatory Alignment
We conduct AML AUPs in accordance with UAE Central Bank and FATF standards, ensuring that all findings and recommendations support full compliance readiness.
Actionable Review Outcomes
Each engagement delivers clear, practical recommendations that help strengthen internal controls, improve monitoring systems, and mitigate financial crime risks.
Commitment to Integrity
IMC’s reviews are designed to enhance transparency, accountability, and trust across your compliance operations, protecting your reputation and business continuity.
Ongoing Compliance Support
Beyond AUP engagements, we assist clients with continuous monitoring, remediation, and updates to keep pace with evolving AML/CFT regulations.
Actionable Review Outcomes
Each engagement delivers clear, practical recommendations that help strengthen internal controls, improve monitoring systems, and mitigate financial crime risks.
Commitment to Integrity
IMC’s reviews are designed to enhance transparency, accountability, and trust across your compliance operations, protecting your reputation and business continuity.
Ongoing Compliance Support
Beyond AUP engagements, we assist clients with continuous monitoring, remediation, and updates to keep pace with evolving AML/CFT regulations.
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FAQs
An AML AUP engagement involves an independent review of specific anti-money laundering procedures agreed upon between the client and the auditor. It focuses on evaluating defined controls, reporting factual findings, and identifying gaps that require corrective action.
Many businesses undergo AML AUP reviews to meet regulatory expectations from authorities like the Central Bank, FSRA (ADGM), or DFSA (DIFC). These reviews help verify that internal AML controls and reporting practices are functioning as required.
An AML audit assesses the overall compliance framework, while an AML AUP focuses only on specific areas chosen by the client or regulator. It is factual, objective, and does not provide an opinion—only observations based on agreed testing steps.
Only independent and qualified firms with AML expertise can conduct AUP reviews. The selected firm must have no conflict of interest and should follow UAE auditing standards and international AML guidelines.
The report provides factual findings highlighting control weaknesses, exceptions, and data inconsistencies. It helps management take prompt action and demonstrate to regulators that the business is committed to maintaining compliance.
Management must prepare a corrective action plan addressing each finding. Ignoring these gaps can lead to fines, account restrictions, or loss of regulatory trust during subsequent inspections.
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