AFSA (AIFC) — Compliance Manual Skeleton

Structure and drafting outline for an AFSA-regulated firm’s compliance manual: governance (SEO/CO/MLRO), client onboarding, AML/CFT & sanctions, client assets, conduct, prudential, outsourcing, resilience, incidents, reporting and monitoring.

Contents (short)

  • Firm & permissions — authorised activities, conditions.
  • Governance — roles, independence, committees.
  • Regulatory map — GEN, COB, PRU, market conduct, AML, DP.
  • Policies — conflicts, PAD, client agreements, disclosures.
  • Client assets — segregation, reconciliations, custody.
  • AML/CFT & sanctions — risk assessment, scoring, monitoring, STR/SAR.
  • Outsourcing — DD, SLAs, oversight, exit.
  • Operational resilience — BCP/DR, IT controls, data protection.
  • Incidents & notifications — breach register, AFSA notices.
  • Reporting & registers — calendar, mandatory logs.
  • Training & competence — fit & proper, refreshers.
  • Compliance Monitoring Plan — risk-based reviews and findings tracking.

Download & next steps

Download the skeleton and map each policy/procedure to your Authorisation, license conditions and latest AFSA rulebooks. We can customise the manual and prepare application packs.