AML Reporting Obligations in the GoAML Portal

Introduction

The goAML portal, developed by the United Nations Office on Drugs and Crime (UNODC), is the UAE’s official platform for reporting suspicious and high-value transactions. Managed by the UAE Financial Intelligence Unit (FIU), it plays a central role in ensuring compliance with the UAE’s Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) laws.

For both financial institutions and Designated Non-Financial Businesses and Professions (DNFBPs), registration and active use of goAML is a legal requirement under Federal Decree-Law No. 20 of 2018 and subsequent cabinet decisions.

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Who Must Use the goAML Portal?

• Financial Institutions (FIs): Banks, money exchange houses, finance companies, insurance firms.

• DNFBPs:

o Real estate brokers and developers.

o Dealers in precious metals and stones (DPMS).

o Auditors and accountants.

o Corporate service providers.

o Lawyers and notaries (when handling client financial transactions).

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Types of Reports to Be Filed in goAML

1. Suspicious Transaction Reports (STRs)

• Mandatory when a transaction appears unusual, inconsistent with a customer’s profile, or raises suspicion of money laundering or terrorism financing.

• STRs must be filed immediately upon detection, regardless of the transaction amount.

2. Suspicious Activity Reports (SARs)

• Similar to STRs but focused on activities rather than specific transactions (e.g., unusual client behavior or attempts to conceal ownership).

3. Cash Transaction Reports (CTRs)

• Required for cash transactions exceeding AED 55,000.

• Applies across DNFBPs and financial institutions to reduce cash-based laundering risks.

4. Other Regulatory Reports

• Some sectors may be required to file cross-border transaction reports, high-risk jurisdiction dealings, or sector-specific reports, depending on guidance from regulators.

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Key Compliance Obligations in Using goAML

1. Registration

• All obligated entities must register on the goAML portal.

• Registration requires company details, licensing information, and the appointment of a Money Laundering Reporting Officer (MLRO).

2. Internal Policies & Systems

• Firms must have documented AML policies and systems in place to detect suspicious activities before filing reports.

3. Timely Reporting

• STRs and CTRs must be filed without delay.

• Failure to report promptly can result in penalties even if the report is eventually submitted.

4. Accuracy of Reports

• Reports must include complete customer details, transaction records, and supporting evidence.

• Incomplete or inaccurate filings may be considered non-compliance.

5. Record-Keeping

• All STRs, CTRs, and supporting documents must be retained for at least five years.

6. Confidentiality

• Businesses must ensure non-disclosure of STR filings to customers or third parties (“tipping off” is a criminal offense).

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Penalties for Non-Compliance

Failure to comply with reporting obligations via goAML can lead to:

• Fines ranging from AED 50,000 to AED 5 million.

• Suspension or cancellation of trade licenses.

• Criminal prosecution in cases of willful negligence.

• Reputational damage due to association with financial crime.

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Best Practices for Businesses

1. Appoint a qualified MLRO and ensure goAML access is secured.

2. Train employees to recognize suspicious activities and escalate to compliance teams.

3. Automate transaction monitoring for early detection of suspicious activity.

4. Test reporting procedures regularly to avoid delays.

5. Stay updated with Ministry of Economy and Central Bank circulars on AML reporting.

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Conclusion

The goAML portal is the backbone of AML reporting in the UAE. By ensuring timely, accurate, and confidential reporting of STRs, CTRs, and SARs, businesses not only comply with the law but also contribute to the UAE’s fight against financial crime.

For all regulated entities, effective use of goAML is both a legal obligation and a business necessity that protects against penalties, reputational damage, and regulatory action.

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About Sheikh Anwar Accounting and Auditing LLC

At Sheikh Anwar Accounting and Auditing LLC, we assist businesses with all aspects of goAML compliance, including:

• goAML registration and portal setup.

• Filing STRs and CTRs on behalf of clients.

• Drafting AML policies and compliance frameworks.

• Outsourced MLRO services.

• AML awareness and staff training programs.

• 📍 Head Office: Dubai, UAE

• 🌐 Website: www.sa-auditors.com

• 📧 Email: info@sa-auditors.com

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