AML Agreed-Upon Procedures
Complete your AML AUP with clear findings and stay ready for reporting deadlines.
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About AML Agreed-Upon Procedures
An Agreed-Upon Procedures engagement, or AUP, is different from a traditional audit. Instead of giving an overall audit opinion, specific procedures are agreed before the engagement begins. These procedures are then carried out, and the factual findings are reported.
Vertex Compliance provides AML AUP services for businesses that need specific checks on their AML/CFT compliance function. For exchange houses, the annual AUP looks at key areas of the AML/CFT framework and how required processes are being followed.
The work can include your AML framework, risk assessments, KYC processes, transaction monitoring, sanctions screening, AML training, suspicious transaction records, compliance reports, and other areas agreed as part of the scope.
At the end of the engagement, you receive a clear record of the procedures completed and the findings identified. This gives the Board, management, and other relevant parties the information they need to understand the results and decide what action is required.
What Our AML Agreed-Upon Procedures Cover
Depending on the scope, the engagement can cover the following areas of your AML/CFT compliance function.
1. AML Framework and Risk Controls
We look at the main documents and controls that form the basis of your AML/CFT programme. This section can cover the compliance framework, AML/CFT policies and procedures, and your ML/FT/PF risk assessments. The agreed checks may also cover the appointment and responsibilities of the Compliance Officer, internal audit reports, and the semi-annual reports prepared by the MLRO or Compliance Officer. Continuous professional development arrangements can also form part of the work. Each procedure is carried out against the agreed requirement. The result is then recorded as a factual finding, giving management a clear view of what the audit focuses on: the specific procedures agreed upon by the relevant parties and reports the findings from those checks. This process is conducted without expanding the engagement to include a broader audit opinion.
2. Customer and Transaction Controls
Much of AML compliance is done through customer due diligence and transactional controls in the course of the day-to-day business. Therefore, the AUP may include KYC processes, customer information, transaction analysis and the management of specific business relationships. Depending on the agreed scope, we may also review transaction monitoring systems, sanctions screening, typology assessments, PEP and HIO checks and the gathering of required customer information or declarations. Where relevant, procedures may cover relationships with DNFBPs and dealers in precious metals and stones. The purpose is to carry out the specific checks already agreed for the engagement and clearly record the outcome of each one.
3. Training, Records and Reporting
AML controls also depend on how people, records, and reporting processes. The management of people, records, and reporting processes across the business also influences AML controls. across the business. The procedures can cover employee recruitment checks, AML training programmes, conflict-of-interest arrangements, suspicious transaction logs, and record-retention practices. We may also include committee meeting minutes and other supporting records as part of the agreed work. For exchange houses, the scope can also include remittance data uploads and other records linked to the AML/CFT compliance function. We document the result of each procedure so the final report provides the relevant parties a clear account of the checks completed and the findings identified.
Our Approach
Our AML Agreed-Upon Procedures approach focuses on specific compliance areas agreed upon before the engagement begins.
Agree on the Scope
We start by defining the objective of the engagement and the procedures needed. The relevant parties should agree on the scope before the work starts. We also verify the records, reports, systems and other information that will be needed to perform those procedures. This keeps the engagement focused and clarifies the AUP’s coverage. It also helps keep the engagement focused and clarifies what the AUP covers specifically and what it does not.
Carry Out the Checks
When the scope is agreed on, our team executes the defined AML/CFT procedures. This may include policies, compliance records, customer information, risk assessments, system outputs, reports, training records or other material associated with the agreed checks. The work is performed according to the agreed procedures. An AUP is never extended to a general audit or a wider assessment unless a separate scope has been agreed.
Record the Findings
We document what was found while carrying out each agreed procedure. If a review identifies an exception, missing record, inconsistency, or another point that needs attention, it is recorded as part of the factual findings. The aim is to provide the people using the report a clear account of the work performed and its results, without adding an audit opinion that falls outside the purpose of an AUP engagement.
Complete the Report
Once the procedures have been completed, the findings will be compiled in the AUP report. The report sets out the procedures performed and the factual results from those checks. Where the engagement is being completed for a regulatory requirement, we also work around the applicable reporting timeline. This gives management and the board the information needed to review the findings and take the appropriate next steps.
Who Is AML AUP For?
Exchange Houses
CBUAE-Regulated Businesses
Financial Institutions
Businesses With Specific AML Checks
Ideal for UAE-regulated businesses that need specific AML/CFT controls independently tested and the factual findings clearly reported.
Why Choose Our AML AUP Service?
AML AUP Expertise
Vertex Compliance has hands-on experience in AML Agreed-Upon Procedures and UAE regulatory requirements. We keep each engagement focused on the agreed scope, required checks and factual reporting needed to produce a clear and reliable AUP.
Clear AUP Scope
You know what will be checked before the engagement begins. We work with you to set out the procedures, information required, key steps, and expected timeline, reducing confusion once the AUP is already underway.
Practical, Clear Findings
Our reports focus on what the agreed procedures actually found. The results are set out clearly so the Board, management, and other intended users can understand the findings without having to work through unnecessary or overly technical language.
On-Time AUP Support
Regulatory AUP work often comes with firm reporting dates. We plan the engagement around the required timeline, keep the process moving, and work with your team to obtain the information needed to complete the agreed procedures on time.
Meet the Experts
Vasantha Madan Mohan
Managing Director
Sridhar Rajam
Associate Partner
Arjun Mohan
Director – Sales & Marketing