Treat an AML findings letter as urgent legal work. Acknowledge within the deadline, preserve records, assemble the facts before conceding anything, and respond with a remediation plan that fixes the root cause rather than the symptom. Administrative penalties under the 2025 framework can be imposed on the firm and on its executives, and written representations on proportionality are usually possible before a penalty is final.
Who inspects whom
VARA supervises Dubai's VASPs outside the DIFC. The DFSA supervises DIFC firms and the FSRA supervises ADGM firms. The Central Bank supervises banks, exchange houses, finance companies and payment and stored value firms. The Capital Markets Authority supervises its licensees. The Ministry of Economy and Tourism supervises real estate brokers and agents, dealers in precious metals and stones, auditors and accountants and corporate service providers, and the Ministry of Justice supervises lawyers and notaries. Each has the power under Federal Decree-Law No. 10 of 2025 and the Executive Regulations to inspect, require information, impose administrative penalties and refer matters onward.
The first two weeks
- Read the letter as a lawyer would. Identify the legal basis cited for each finding, the deadline, whether a response or a remediation plan or both is required, and whether a penalty is proposed or merely reserved.
- Acknowledge within the deadline and, if more time is genuinely needed, ask for it with reasons before the deadline passes, not after.
- Preserve everything. Onboarding files, alert logs, screening records, emails and board papers for the period under review. Deleting or amending records after a findings letter converts a compliance problem into a conduct problem.
- Assemble the facts before conceding. A finding that "enhanced due diligence was not performed" is often a finding that it was performed and not documented, or documented in a system the inspector did not see. Each of those is a different response.
- Engage the board. Senior management and directors are personally exposed to administrative penalties under the 2025 framework. The board should be told at once and should approve the response.
The response
A good response does three things. It corrects any factual errors in the findings with evidence. It accepts what is genuinely deficient without argument. And it attaches a remediation plan that addresses root causes: not "we will update the policy" but "the customer risk model did not weight country risk because it was built before the firm served customers in that region; the model has been rebuilt as attached, all existing customers have been re-scored, and the twelve now rated high-risk have been subjected to enhanced due diligence with the results attached." Owners, dates and the evidence that will prove closure are stated for each item.
Where a penalty is proposed, the response should also make written representations on proportionality: the firm's size and history, the absence of actual harm, self-identification where it occurred, the speed and completeness of remediation and the governance response. Regulators have discretion and they use it when the submission gives them a reasoned basis to do so.
After the response
Remediation is tracked to closure through the MLRO's board reports, and closure evidence is filed with the regulator on the dates promised. Where the regulator imposes licence conditions or requires an independent review, the review is scoped with the findings in mind. See independent AML review. For Dubai VASPs, our VARA enforcement letter guide describes that regulator's process in detail.
Where we come in
We take over the correspondence from the first letter, assemble the factual record, draft the response and the remediation plan, make the representations on penalty and manage the closure evidence. Where the matter escalates to formal enforcement or criminal referral, we work with instructed advocates for any onshore court proceedings. See the AML compliance practice page.
Frequently asked questions
What should we do first when we receive an AML findings letter?
Identify the legal basis, deadline and whether a penalty is proposed; acknowledge within the deadline; preserve all records for the period; assemble the facts before conceding any finding; and inform the board, whose members are personally exposed under the 2025 framework.
Can AML fines in the UAE be imposed on directors personally?
Yes. Federal Decree-Law No. 10 of 2025 and the Executive Regulations provide for administrative penalties on the firm and on its executives and senior management, and the Ministry of Economy and Tourism's circulars say so expressly for DNFBPs.
Can we challenge a proposed AML penalty?
Usually yes, by written representations before the penalty is final, addressing the firm's size and history, absence of harm, self-identification, remediation and governance response. The specific appeal route depends on the regulator and the instrument imposing the penalty.
What makes a remediation plan credible to a regulator?
Root cause analysis rather than symptom fixes, named owners, dates, and a statement of the evidence that will prove closure for each item, followed by closure evidence actually delivered on those dates.
Should we delete or correct records after an inspection letter?
No. Preserve everything as it was. Correcting or deleting records after a findings letter turns a compliance deficiency into a conduct issue and can attract separate penalties.
This article is general information on the position at the date shown and is not legal advice. AML obligations turn on the licence, the regulator and the facts of each business; speak to us before relying on it.
