The United Arab Emirates has been actively fighting money laundering (ML) and terrorism financing (TF) using advanced regulatory frameworks and compliance systems. Among those, one of the most important is the reporting system for suspicious activities using the goAML system. Introduced by the United Nations Office on Drugs and Crime (UNODC), the goAML portal serves as one of the major instruments to prevent and detect financial crimes in this country.

Also read: Anti Money Laundering Specialist in UAE

This article describes the goAML system, its requirements in terms of registration, and compliance procedures in the United Arab Emirates (UAE).

What is the goAML System?

The goAML system was developed by the United Nations Office on Drugs and Crime (UNODC) with the aim of combating money laundering and the financing of terrorism. This is known to be an integrated system used by the Financial Intelligence Unit (FIU) to receive, analyze and distribute suspicious transaction reports (STRs) efficiently and as quickly as possible. It is presently used by a big number of financial intelligence units around the world, while the UAE is the first in the Gulf to implement this modern system.

Main Features of the goAML System

Collection and Analysis: The system enables the effective collection of data regarding money laundering and financing of terrorism. This helps the relevant authorities in the decision-making process for appropriate investigation.
Suspicious Transaction Monitoring: The goAML portal monitors suspicious activities, leading to the identification of ML/FT events.
Information Collation: The portal brings together information emanating from financial institutions and DNFBPs and analyzes suspicious transactions.

Purpose of the goAML System

The key concepts of the goAML system involve the improvement in reporting and managing suspicious transactions through the introduction of laws and regulations in the UAE. It can manage several forms of reporting on ML/FT through the platform used by authorized users.

It essentially assists the government in the UAE by making the financial ecosystem more transparent and bringing it to international standards to preserve the integrity of the UAE’s economy.

Who is Required to Register on the goAML Portal?

According to Federal Decree Law No. (20) of 2018 and Cabinet Decision No. (10) of 2019, a person shall have an obligation to register on the goAML portal in case of suspicion, which will be treated as mandatory registration for such entities.

This includes:

Financial Institutions: Banks, exchange houses, and other financial intermediaries.
Designated Non-Financial Businesses and Professions (DNFBPs):
- Dealers in Precious Metals and Stones
- Real Estate Agents and Brokers
- Auditing and Accounting Firms
- Lawyers, Notaries, and other legal professionals
- Trust and Company Service Providers
Virtual Asset Service Providers (VASPs): Entities that provide cryptocurrency services or handle virtual assets.

Registration on the goAML Portal is Mandatory for Designated Non-Financial Companies

All DNFBPs are required to register on the goAML portal. The goAML portal is an integrated system to file STR and/or SAR. Federal Decree Law No. (20) of 2018 and Article 20(2) of Cabinet Decision No. (10) of 2019 state that every entity has an obligation to provide a procedure that includes reporting suspicious transactions to manage anti-money laundering (AML). Such a mechanism helps authorities track and identify criminal and suspicious activity.

Also read: Anti Money Laundering Laws and Regulations in UAE

Non-registration in goAML can result in strict penalties imposed by the Ministry of Economy. If you have not submitted your application, please do so at the earliest to access the goAML system.

Why is goAML Registration Necessary in UAE?

Failure to register on the goAML portal is a violation of UAE’s Anti-Money Laundering (AML) law. Non-registration attracts heavy penalties ranging between AED 50,000 and AED 1 million, apart from severe reputational damage for non-compliant entities.

Thus, the goAML system ensures that any compliance issue in the UAE is taken care of, acting as a unique channel for filing STRs and other reports required by law. Without proper registration, no reporting can be filed by respective entities for such reports, which are essential in the fight against financial crime.

Reports Filed via the goAML Portal in UAE

Several types of reports can be submitted through the goAML portal, ensuring that all suspicious activities are adequately reported to the UAE FIU:

Report Type	Purpose	When to File
Suspicious Transaction Report (STR)	To report suspicious transactions involving ML/FT during business relationships or transactions.	Upon noticing suspicious financial behavior.
Suspicious Activity Report (SAR)	To report suspicious activities or attempted transactions related to ML/FT.	As soon as any suspicious activity is detected.
Dealers in Precious Metals & Stones Report (DPMSR)	For transactions involving precious metals and stones equal to or exceeding AED 55,000 in cash or wire transfers.	The report must be submitted within 2 weeks of the transaction involving cash or wire transfer.
High-Risk Country Transaction Report (HRC)	To report transactions with high-risk countries.	When conducting transactions with high-risk countries as defined by the UAE government.
Real Estate Activity Report (REAR)	To report cash or virtual asset real estate transactions.	When real estate agents, brokers, or lawyers are involved in real estate transactions using cash or virtual assets.
Fund Freeze Report (FFR)	To report the freezing of funds related to sanctioned individuals or entities.	When funds are frozen due to a confirmed match with the sanctions list.
Partial Name Match Report (PNMR)	To report any ‘partial match’ with the UAE’s sanctions list.	When a partial match is identified during customer due diligence.

Deadlines for goAML Registration

The deadline for the registration of existing companies on the goAML portal was April 30, 2021. The registration for new companies should, however, be performed within a reasonable time after their constitution.

Steps for goAML Registration in UAE

Register in the SACM System:
- Access the Service Access Control Manager (SACM) system of the UAE Financial Intelligence Unit (FIU).
- Obtain a username and a secret key for the Google Authenticator application.
Set Up Google Authenticator:
- Use the secret key to install the Google Authenticator app.
- Generate a unique code from the app, which will serve as your password to access the goAML portal.
Complete the goAML Portal Registration:
- Log in to the goAML portal using your username and the code from Google Authenticator.
- Provide detailed information about your organization and the Compliance Officer.
Submit Required Documents:
- Make sure you have all necessary documents, such as identification and proof of address for the Compliance Officer.
Verification and Approval:
- Wait for the FIU to verify your information and approve your registration.

Upon successful registration, the organization will be authorized to file suspicious transaction reports (STRs) and other filings under the goAML system.

Documents Required for goAML Registration in UAE

The following documents are required for the successful completion of the goAML registration:

Authorisation letter from the institution you represent
A copy of your passport, resident visa, and Emirates ID
A copy of the commercial trade license (for companies)
Download the ‘Google Authenticator’ application on your phone. (This application contains the password for the SACM protection system, which will change every minute).

Penalties for Non-Compliance

It is important to understand the significance of completing the post-registration procedures and measures to avoid the fines set by the Cabinet Resolution No. 16 of 2021. These fines range from AED 50,000 to up to AED 1 million and can be doubled up to AED 5 million based on the provisions of the law and according to the assessment of the Supreme Committee for Combating Money Laundering, and Financing of Terrorism and Illegal Organisations.

Furthermore, failing to report suspicious transactions could make the entity liable for further legal liabilities.

How Farahat & Co. Can Assist

It is essential for financial institutions, DNFBPs, and VASPs that their operations in the UAE remain AML-compliant. The goAML system would mean businesses are considerably well-placed to fulfill the legal requirements on reporting suspicious transactions.

Our AML professionals can provide AML compliance services at Farahat & Co., including assisting in goAML registration, drafting the relevant documentation, and advising upon the filing of reports with the UAE FIU.

Make sure your business is in compliance; reach out today for professional guidance in this respect.