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AML/CFT Gap Assessment

Spot weaknesses in your AML/CFT framework and focus on the fixes that matter most.

Request a Gap Assessment

    What Our AML/CFT Gap Assessment Reviews

    We check the key areas of your AML/CFT setup to find gaps and weak controls.

    1. Governance, Policies and Risk Assessment

    We start with the documents and responsibilities that sit at the centre of your AML/CFT programme. This may include AML/CFT policies, internal procedures, roles and responsibilities, risk assessments, governance arrangements and how issues of compliance are managed across the business. We also consider whether these documents remain consistent with the way your organisation operates today. For example, your customers, services, products, locations or risk exposure may have changed since the policy was written. If the framework has not kept pace, then even if the documents themselves appear complete, there can be gaps. The review can help you identify areas where responsibilities need clarifying, where documents need updating and whether your risk approach still reflects the business you are running today.

    2. Customer Controls, Screening and Monitoring

    This part looks at what happens once customers enter your business. We check areas such as KYC, customer due diligence, customer risk ratings, sanctions screening, ongoing reviews, transaction monitoring, and escalation. The focus is not just on whether a process exists. We also look at whether it is being followed in a way that makes sense for the risk involved. Higher-risk customers, unusual activity, screening alerts, and changes in customer behaviour may all need closer attention. We look at how those situations are handled and whether the decisions made are properly recorded. This can uncover gaps that are easy to miss when you only read the policy and do not look at how the process is working in real cases.

    3. Training, Reporting and Escalation Records

    AML/CFT controls rely on people knowing what to do and being able to show that the work was done. We look at training records, internal reports, review notes, approvals, supporting documents, and other records linked to the compliance process. Training is also considered to see whether employees are receiving the information they need for their roles. Record-keeping matters just as much. If an important decision cannot be supported by a clear record, it may be difficult to explain later during a review or inspection. We therefore look for missing documents, outdated records, unclear approvals, and areas where the evidence does not fully support the process being followed.

    Our Approach

    We first understand your business, review what’s in place, find the gaps, and show what needs attention.

    1
    Understand Your Business

    First, we seek to understand how your business operates. We evaluate your customers, business activities, locations and primary risk areas. We also look into the requirements of your organisation to gain the right context. This helps us tailor our solutions to your business, instead of treating every business in the same way.

    2
    Review What You Have

    In the next step, we go through the AML/CFT setup that is already in place. This includes policies, processes, risk assessments, customer records, screening information, monitoring processes, training records, internal reports, and other documents within the agreed scope. We look at the written process, but we also pay attention to how the work is actually being carried out.

    3
    Find and Prioritise the Gaps

    Once the review is underway, the weak areas start to become clearer. Some gaps may be small and easy to fix. Others may need more attention because they affect an important part of the AML/CFT process. We group the findings so your team can see what should be handled first and what can be dealt with as part of a longer-term improvement plan.

    4
    Plan the Next Steps

    The assessment should leave you knowing what to do next. We explain the gaps in clear language and give practical recommendations for dealing with them. That may mean updating a policy, improving a control, keeping better records, changing part of a process, or making responsibilities clearer. The goal is to give your team a sensible way forward, not another report that is difficult to use.

    See What’s Missing in your AML/CFT Controls

    Who Is AML/CFT Gap Assessment For?

    Banks and Financial Institutions
    Designated Non-Financial Businesses & Professions
    Virtual Asset Service Providers
    Businesses Handling High-Value Cash Transactions

    Ideal for UAE-registered businesses preparing for or responding to regulatory examinations. AML/CFT controls may be the entry.

    Why Choose Vertex for Your AML/CFT Gap Assessment?

    Built Around Your Business

    Your AML/CFT risks depend on the way your business operates. We take your industry, customers, services, activities, regulatory requirements, and risk profile into account when carrying out the assessment. That keeps the review relevant to your business rather than turning it into a standard checklist exercise.

    Look Beyond the Documents

    A policy can look complete while the process behind it is not working the same way. We look at both sides. The written framework is reviewed alongside the way controls are being used in practice. This can bring out problems in screening, customer reviews, escalation, record-keeping, or other areas that may not be obvious from documents alone.

    Clear, Prioritised Findings

    A long list of findings is not much help if you do not know where to begin. We make the gaps easy to understand and organise them by importance. Your team can quickly see what needs closer attention and what can be dealt with later as part of wider improvements.

    Support Beyond the Assessment

    Finding the gap is only the first part. If you need help after the assessment, Vertex Compliance can support your team with the next steps. That may include updating policies, improving controls, making responsibilities clearer, or working through the actions needed to address the issues found.

    Meet the Experts

    Sarah Khan
    Vasantha Madan Mohan

    Managing Director

    Sarah Khan
    Sridhar Rajam

    Associate Partner

    Sarah Khan
    Arjun Mohan

    Director – Sales & Marketing

    Would Your AML/CFT Controls Pass a Regulatory Review?

    Frequently Asked Questions

    Not every business has a set timeline. It is contingent upon the size of the organisation, the scope of the review, the level of risk and the amount of information that needs to be checked. Once we understand the work, we can give you a clearer idea of the time scale.
    The documents depend on the magnitude of the assessment. AML/CFT policies and procedures, risk assessments, customer due diligence records, screening information, monitoring records, training documents, internal reports and other supporting material.
    Yes. In many cases, most of the work can be completed through document reviews and online meetings. If there is a need to look more closely at a process or how it works on site, an on-site review may also be recommended.
    You will get a clear view of the gaps identified, the areas requiring attention and practical recommendations on how to address them. The findings can then be used to decide what should be fixed first and what can be scheduled for later.
    Yep. If you need support after the assessment, Vertex Compliance can assist with policy updates, control improvements, responsibilities, documentation and other actions linked to the gaps identified during the review.
    Yes. The assessment considers your industry, jurisdiction, business activities, regulatory requirements and risk profile. The review is based on the AML/CFT requirements relevant to your organisation.