AML Software Migration Checklist

Who this checklist helps

Use it if your UAE regulated business is replacing an AML screening, customer due diligence, monitoring or case-management platform. It gives compliance officers a record-preservation checklist, operations teams practical checks on customer files, and IT teams clear transfer and verification questions to resolve with vendors. Business owners can use the summary to see what remains outstanding before approving the switch.

How the checklist helps you prepare

A customer list is only part of an AML record. Documents, screening decisions, risk assessments, open alerts and the history behind an approval may sit in different parts of the old platform. A migration plan helps you identify what must move, what needs a separate archive and what must be checked before access ends.

• Prepare a clear record inventory and agree what the new provider can import.
• Keep customer records linked to their supporting documents and decision history.
• Spot missing exports, unreadable files and records changed during the move.
• Give the responsible person a clear list of outstanding checks before sign-off.

How to use the interactive checklist

Work through the five checklist stages with the people responsible for your software change. The final screen brings your answers together.

1. Tick each of the 16 items only when you have completed the check. Open Quick tip for a practical example.
2. Use the optional fields for the business name, old and new software, planned moving date and outstanding actions. Keep notes general.
3. Download my report (PDF) or use Print my report before closing or refreshing the page. Your ticks and notes are held only in the open page and are not saved for your next visit.

Save your checklist as a PDF and preserve your records

Your PDF report brings together all 16 checklist items and their completion status, the optional business and software details, the planned moving date and your notes. Download it before leaving the page, then keep it in your approved migration project folder. Use it to discuss unfinished actions with your team and retain a record of what you entered.

The PDF contains your checklist answers, not the underlying customer records. Exported Excel or CSV files, PDF reports, scans, supporting documents and original paper files must be saved and protected separately. Keep an index of where they are held, who can access them and how long they must be retained. Check that archived files open and can be retrieved when needed.

Five stages to plan your AML software migration

1. 1

   Before you start

   Agree the moving date, responsibilities and what the new software can import. Check notice periods, export fees and remaining access with the old vendor. Plan how ongoing screening, monitoring and case handling will continue during the move.

2. 2

   Save your spreadsheets

   Export customer lists and relevant AML data to Excel or CSV. Include customer identifiers, beneficial owners, risk ratings, screening results, alerts and transaction records where applicable. Open the files and check totals, dates, important columns and unreadable or missing entries. CSV exports do not automatically include attachments.

3. 3

   Download documents and keep papers

   Save PDF reports, KYC forms, scans, approvals and supporting documents. Preserve past checks, decisions and audit trails, including who acted and when. Keep original physical records securely; label and log any paper-file handover. A downloaded scan is not the same as an original paper record.

4. 4

   Move the records securely

   Agree a supported spreadsheet import or API transfer with your vendors. An API is a direct system-to-system connection; use it only where both systems support the required transfer and your authorised IT team sets it up. Restrict access, use an approved secure transfer route and confirm the destination and applicable data-transfer requirements. Check that customer records and documents stay linked.

5. 5

   Check before closing

   Open sample records in the new system, reconcile totals and date ranges, and resolve missing or rejected imports. Include records changed after the first export. Test user access, document retrieval and relevant screening or monitoring functions. Keep a secure, accessible archive of anything the new system cannot hold. Obtain approval before closing the old account, with any read-only period or contingency agreed.

Record retention during AML software migration

Changing providers does not remove your record-keeping obligations. Article 25 of Cabinet Resolution No. (134) of 2025 addresses retention and prompt availability of AML records. Ask your compliance officer to confirm the applicable period, its starting point, any additional supervisory requirements and any investigation or legal hold for each record category. Keep records accessible throughout the transition and afterwards.

Read the official record-keeping requirements

Frequently asked questions