Baker Tilly’s Comprehensive Approach to Audit and Technology Assessment in Response to CBUAE Notice No. 4140.2025
Driving Compliance, Resilience, and Innovation in the UAE’s Exchange and Remittance Sector
In today’s dynamic financial landscape, regulatory authorities are intensifying their focus on the robustness and security of digital platforms. The Central Bank of the UAE (CBUAE) has taken a significant step by issuing Notice No. 4140.2025, mandating regulated financial institutions, particularly those operating in the exchange and remittance sector, to undertake a thorough review of their core technology systems. This notice aims not only to ensure regulatory compliance but also to elevate technical architecture and cybersecurity resilience across the industry to protect public interest.
Understanding the Scope: What Does CBUAE Notice 4140.2025 Require?
At its core, Notice No. 4140.2025 requires financial institutions to critically assess their technology environments. This is not simply a matter of ticking boxes; it is about embedding operational excellence and future-readiness into the very fabric of financial service delivery. The review must cover:
- Core Systems Review: Scrutinising the scalability, modularity, and integration capabilities of digital platforms and backend systems to ensure they can support evolving business needs.
- Cybersecurity Assessment: Evaluating the institution’s threat detection mechanisms, the security of privileged access, mobile/API protection, and the robustness of incident response protocols, all aligned with CBUAE’s Information Security standards.
- Regulatory Alignment: Verifying that governance frameworks, audit trails, and oversight of third-party vendors meet the stringent requirements of the notice.
- Benchmarking: Comparing the institution’s technology stack against leading global FX and remittance platforms to uncover opportunities for enhanced resilience, speed, and automation.
- Future-Readiness: Reviewing disaster recovery plans, uptime service level agreements (SLAs), and readiness for hybrid cloud adoption to ensure business continuity and adaptability.
Baker Tilly’s Value-Driven Methodology
At Baker Tilly, we believe that regulatory compliance should be a catalyst for organisational learning and continuous improvement. Our methodology is designed to deliver not only compliance but also actionable insights that drive business value.
Methodology Overview
Our approach is grounded in evidence and shaped by deep industry knowledge. The process is both systematic and collaborative, ensuring that recommendations are practical and tailored to each client’s operational realities.
| Step | Key Activities | Outcome |
| 1. Document Review & Stakeholder Interviews | Analyse policies, architecture, and operations; gather insights from key personnel | Establishes baseline understanding and context |
| 2. System Walkthrough & Technical Analysis | Perform hands-on review of systems, integrations, and controls | Identifies architectural and operational gaps |
| 3. Cybersecurity Evaluation & Benchmarking | Assess security posture versus CBUAE and global standards | Highlights vulnerabilities and best practice gaps |
| 4. Risk-Based Recommendations | Prioritise findings based on business impact and regulatory risk | Enables informed decision-making and targeted remediation |
What Sets Baker Tilly Apart?
- Our team have delivered successful outcomes for banks, fintechs, and remittance companies across the region.
- We bring together specialists in audit, risk, cybersecurity, and advisory services, ensuring a 360-degree perspective on every engagement.
- Our assessments are mapped to international standards such as ISO 27001, NIST, GDPR, and DPDP, enabling clients to achieve both local and global compliance.
- We go beyond technical findings to deliver recommendations that are relevant, prioritised, and aligned with each institution’s strategic objectives.
Key Learnings for Financial Institutions
The regulatory landscape is evolving rapidly, and the CBUAE’s Notice reflects a broader shift towards heightened oversight and digital resilience. Institutions that treat compliance as an opportunity for learning and transformation will be better equipped to:
- Enhance operational efficiency and customer trust by building secure, scalable digital platforms.
- Proactively address cybersecurity risks and regulatory expectations.
- Benchmark and adopt global best practices in technology and governance.
- Future-proof their organisations for the next wave of digital innovation and regulatory change.
Supporting the Journey: How Baker Tilly Can Help
As financial institutions in the UAE prepare to address the requirements of CBUAE Notice 4140.2025, Baker Tilly stands ready to assist with:
- Independent audits and comprehensive gap assessments
- Cybersecurity and information security (InfoSec) reviews
- Digital transformation and cloud readiness evaluations
- Benchmarking against global best practices
By partnering with Baker Tilly, organisations can not only ensure compliance but also unlock new levels of resilience, agility, and competitive advantage in an increasingly digital world.
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