Maker-Checker Controls for goAML Reporting in the UAE

Accurate AML reporting requires more than identifying potentially suspicious activity. Businesses also need a reliable process for reviewing information before a report is submitted. A maker-checker control can help UAE businesses introduce an additional level of review into their AML reporting workflow.

The maker-checker principle separates the person who prepares or "makes" a report from the person who reviews or "checks" it. Instead of allowing one individual to prepare and submit an AML report without independent review, the process introduces a second level of verification.

For businesses using goAML, this approach can help create a more structured reporting process and reduce avoidable errors before submission.

What Is a Maker-Checker Control?

A maker-checker control is an internal control where one employee prepares an activity and another authorised employee independently reviews it before it is completed or submitted.

In an AML reporting process, the maker may be responsible for collecting relevant information, reviewing the case, preparing the report, and entering the required information.

The checker independently reviews the information before the report proceeds to the next stage.

The checker may verify whether:

• Customer information is accurate.
• Transaction information is consistent with supporting records.
• The reason for reporting is clearly documented.
• Relevant information has been included.
• Supporting evidence has been reviewed.
• Required fields have been completed.
• The report is consistent with the underlying investigation.

The exact responsibilities should be defined in the organisation's internal AML procedures.

Why Are Maker-Checker Controls Important for AML Reporting?

AML reports can contain information collected from several systems and departments. A simple data-entry mistake, missing information, or incorrect reference can affect the quality of the report.

A maker-checker process creates an opportunity to identify such issues before submission.

Reduces Single-Person Dependency

When one person controls the entire reporting process, there may be limited opportunity for another employee to identify an error.

Separating preparation and review creates an additional control point.

Improves Report Quality

The checker can review the report against the organisation's records and AML procedures.

This can help identify incomplete or inconsistent information before the report is submitted through the relevant reporting process.

Creates Clear Accountability

A properly designed maker-checker process establishes who prepared the report and who reviewed it.

This creates a clearer audit trail and can help management understand how reporting decisions were processed.

Supports Consistent Processes

Different employees may approach AML reporting differently if there is no standard review process.

A maker-checker workflow can establish consistent steps for preparation, review, approval, and submission.

How Does Maker-Checker Work With goAML Reporting?

The exact workflow will depend on the organisation's internal systems and responsibilities.

A practical process may begin when an AML alert or investigation requires further consideration.

The maker reviews the relevant customer and transaction information and prepares the report according to the organisation's procedures.

The report then moves to the checker for independent review.

The checker reviews the information and either:

1. Approves the report for the next stage.
2. Returns it to the maker for correction or clarification.
3. Escalates an issue to the appropriate compliance authority.

After required corrections are completed, the report can proceed through the organisation's approved reporting workflow.

The important principle is that the checker should perform a genuine review rather than simply confirming that the maker has completed the form.

What Should the Maker Check Before Review?

The maker should complete an initial quality check before sending the report to the checker.

This can include verifying customer identification information, transaction details, dates, amounts, account or reference information, relevant parties, and the underlying reason for the report.

The maker should also make sure that supporting investigation information is properly documented.

If the organisation has an internal AML investigation file, relevant evidence should be reviewed before the report is prepared.

This can reduce the number of basic errors reaching the checker.

What Should the Checker Review?

The checker should perform an independent review rather than simply repeating the maker's work.

The review may cover several areas.

Customer Information

The checker can compare important customer information against the organisation's KYC records.

Transaction Information

Transaction dates, amounts, references, counterparties, and other relevant details can be checked against the underlying records.

Case Information

The checker can determine whether the report is consistent with the investigation and documented case information.

Reporting Rationale

The checker can review whether the reason for reporting is clearly and consistently documented according to the organisation's procedures.

Data Completeness

The reviewer can check whether relevant fields have been completed and whether important information is missing.

Supporting Evidence

Where applicable, the checker can confirm that relevant supporting records have been considered and appropriately documented.

Common Maker-Checker Mistakes

A maker-checker control can become ineffective if it is treated as a simple approval step.

One common problem is rubber-stamping, where the checker approves a report without actually reviewing it.

Another issue is allowing the same person to perform both roles. This removes the independence that the control is intended to provide.

Businesses should also avoid creating unnecessary delays. If every report requires multiple manual reviews without clear responsibilities, the process can become inefficient.

The solution is to establish a clear review scope and define which issues require escalation.

How to Build a Maker-Checker Workflow

Businesses can introduce the control through a structured process.

Step 1: Define the Maker Role

Document exactly what the maker is responsible for.

This may include information gathering, case review, report preparation, data entry, and initial quality checks.

Step 2: Define the Checker Role

Specify what the checker must independently verify.

The checker should understand the organisation's AML procedures and the information relevant to the reporting process.

Step 3: Create a Review Checklist

A standard checklist can help ensure that important areas are reviewed consistently.

The checklist can cover customer information, transaction information, supporting evidence, reporting rationale, completeness, and internal references.

Step 4: Define Escalation Rules

Not every issue should be handled in the same way.

The organisation should establish what happens when the checker identifies missing information, inconsistencies, or a significant concern.

Step 5: Maintain an Audit Trail

The organisation should retain appropriate records showing who prepared, reviewed, amended, and approved the report, according to its recordkeeping procedures.

This can make the reporting process easier to review later.

Maker-Checker Controls and AML Data Quality

Maker-checker controls work particularly well when combined with good AML data-quality practices.

A data dictionary can define what important fields mean, while the maker-checker process verifies whether those fields have been correctly used in a particular report.

For example, if an organisation has defined a standard format for customer identification, the maker can apply the standard and the checker can verify it.

This creates two complementary controls:

Data standards → Preparation → Independent review → Reporting

Together, these controls can provide a more structured approach to AML reporting.

How Technology Can Support Maker-Checker Controls

Technology can help organisations manage maker-checker workflows more efficiently.

Depending on the organisation's systems, technology may be used to:

• Assign cases to specific employees.
• Record review status.
• Track changes.
• Maintain timestamps.
• Create approval workflows.
• Identify incomplete information.
• Maintain user activity records.
• Generate management reports.

However, technology does not replace the need for appropriate human review. A checker still needs to understand the information being reviewed and follow the organisation's AML procedures.

Practical Tips for UAE Businesses

When implementing maker-checker controls for AML reporting, businesses should:

• Separate preparation and review responsibilities where appropriate.
• Define both roles clearly.
• Use a consistent review checklist.
• Make the checker perform a genuine independent review.
• Document corrections and escalations.
• Maintain appropriate audit records.
• Train employees on their responsibilities.
• Periodically test whether the control is operating effectively.
• Review recurring errors to identify process improvements.
• Keep the workflow aligned with the organisation's current AML procedures.

Conclusion

A maker-checker control for goAML reporting in the UAE can provide an additional layer of quality control by separating report preparation from independent review.

The maker focuses on collecting information and preparing the report, while the checker verifies important details before the report proceeds through the organisation's approved reporting workflow.

The effectiveness of the control depends on clear responsibilities, meaningful review, appropriate documentation, and proper escalation procedures. Simply adding a second approval without genuine review does not provide the same level of control.

When combined with strong AML data-quality practices, documented procedures, and appropriate technology, a maker-checker process can help UAE businesses create a more consistent and traceable AML reporting workflow.

Frequently Asked Questions

1. What is a maker-checker control in AML reporting?

A maker-checker control separates report preparation from independent review. One employee prepares the AML report, while another authorised employee reviews the information before it proceeds to the next stage.

2. Why is maker-checker important for goAML reporting?

It can provide an additional quality-control step before reporting. A second reviewer may identify incomplete, inconsistent, or inaccurate information that was missed during preparation.

3. Who should be the maker and checker?

The organisation should define the roles according to its AML structure, responsibilities, and internal procedures. The checker should have sufficient knowledge and authority to perform an independent review.

4. Should the maker and checker be different people?

The purpose of maker-checker is to introduce separation between preparation and review. Therefore, organisations should design the process so that the review is genuinely independent and not simply performed by the same person.

5. What should a checker review before AML reporting?

The checker may review customer information, transaction details, case information, reporting rationale, data completeness, supporting evidence, and consistency with the organisation's records and AML procedures.

6. Does maker-checker guarantee that an AML report is correct?

No. It is an internal control designed to improve the review process. Its effectiveness depends on the quality of the review, the competence of the employees involved, and the organisation's wider AML controls.

7. How can businesses improve maker-checker controls?

Businesses can improve the process by defining responsibilities, creating standard review checklists, documenting escalations, maintaining appropriate audit trails, training employees, and periodically testing whether the control is operating effectively.

8. Can technology support maker-checker controls?

Yes. Depending on the systems available, technology can help manage assignments, approvals, status tracking, audit trails, timestamps, and workflow controls. Human review remains important for evaluating the underlying AML information.