Case Studies

Illustrative outcome scenarios

These are anonymised, composite scenarios.

Note: The following are illustrative composite scenarios based on typical engagements, not accounts of specific named clients. Details have been generalised and combined to demonstrate the kind of work we do while protecting client confidentiality — we don't publish real client case studies without their explicit consent.

DNFBP registration scoping

A Dubai-based brokerage clarifies its registration position

Situation

A mid-sized real estate brokerage handling both off-plan and secondary-market sales was uncertain whether all of its transaction types fell within Cabinet Resolution 134 of 2025's DNFBP scope. Internal opinions differed, and no formal assessment had been done.

What we did

Compass & Coin ran a registration-scoping assessment across the brokerage's transaction types and revenue lines, mapped each against the DNFBP criteria, and produced a written scoping memo. Where activities were in scope, we supported the firm through DNFBP registration and drafted the accompanying AML/CFT policy manual.

Outcome

The brokerage registered as a DNFBP with a clear, documented rationale for its scoping decisions, and had a policy manual in place ahead of its next supervisory review.

Audit-readiness engagement

A property management firm prepares for a supervisory review

Situation

A property management firm with an existing AML/CFT programme had never tested it against a formal review. Leadership wanted assurance the programme would hold up before a scheduled supervisory audit.

What we did

We ran a mock regulatory audit against the firm's existing CDD files, screening records, and reporting logs, benchmarked against CBUAE guidance and FATF expectations. We flagged gaps in documentation completeness and re-screening frequency, and worked with the compliance team to close them before the real audit date.

Outcome

The firm entered its supervisory review with remediated files and a documented action log showing the gaps identified and closed, rather than discovering the gaps during the audit itself.

SAR/STR support

A developer's sales team escalates an unusual transaction

Situation

A developer's sales team flagged a high-value off-plan purchase involving a third-party payment structure that didn't match the buyer's stated profile. The firm's designated MLRO wanted an independent view before deciding whether the transaction met the threshold for a filing.

What we did

Compass & Coin reviewed the transaction details and supporting documentation against red-flag indicators and advised that the pattern warranted a Suspicious Transaction Report. We supported the MLRO in preparing the filing content and walked the team through the goAML submission process — the filing itself remained the client's own regulated action.

Outcome

The firm filed its STR within the appropriate timeframe, with a documented rationale for the decision, and used the episode to tighten its internal escalation process for future flags.