goAML registration is a compliance requirement that forces the financial institutions, as well as Designated Non-Financial Businesses and Professions (DNFBPs) in the UAE, to report suspicious transactions, money laundering, and terrorism financing transactions. The system is an electronic reporting system that has been created by the United Nations Office on Drugs and Crime (UNODC) and introduced locally by the UAE Financial Intelligence Unit (FIU).
The ultimate goal of go Anti-Money Laundering (goAML) is to assist authorities in identifying financial offences, enhancing the control of AML, and remaining in compliance with the international standards of the Financial Action Task Force (FATF). Failure to register goAML in the UAE may lead to regulatory fines and penalties, as well as enforcement under the federal AML laws.
The mandatory registration of regulated individuals onto the goAML electronic reporting platform to provide Suspicious Transaction Reports (STRs), Suspicious Activity Reports (SARs), and other compliance-related reports.
The platform facilitates safe exchanges between regulated parties and the UAE FIU to help the country in its fight against money laundering and financing of terrorism.
Key facts:
The goAML registration is not merely administrative but one of the fundamental pillars of the AML framework in the UAE.
Key objectives include:
In the case of business, good goAML registration will show that it is committed to the regulations and minimizes the exposure to enforcement risks.
Upon successful registration, the organization will be authorized to file suspicious transaction reports (STRs) and other filings under the goAML system.
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The following documents are required for the successful completion of the goAML registration:
According to the UAE legislation, the following parties are to register for goAML:
Any business that comes under the UAE AML supervision should have an AML compliance officer and a goAML registration.
The UAE regime on AML is governed by:
Anti-Money Laundering and Combating the Financing of Terrorism Federal Decree Law No. 20 of 2018. Cabinet Decision No. 10 of 2019 (amended).
The fortification of administrative penalties and supervisory powers through Cabinet Decision No. 109 of 2023.
Recent updates emphasise:
Transactional Training and AML Certification
It is not compulsory to have an anti-money laundering certificate, but you should follow the rules. It is important to understand that qualified people are in a better position to work as an AML compliance officers or MLROs.
The certificates that you will need are:
AML Compliance Solutions
The major standard professional AML compliance solutions in the UAE usually involve:
Increasingly, businesses within the AML jurisdiction of Dubai utilise external advisors to ensure compliance.
The goAML System: What Does it Do?
The goAML system is a centralised reporting portal. The activities done by it are:
The system is confidential, traced and safe in exchange of data
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Late or absent GoAML registration is classified as non-compliance and is dealt with immediately.
In the first step it is necessary to inform the supervising authority. Organizations are required to report to their corresponding supervisory authority or the Ministry of Economy.
The UAE has a two-phase procedure of registration:
You will need to follow both the process and get the registration done
You will need to fill the pre-registration form with different details. These details include:
The quicker the remedial intervention lesser the punishment
Ordinary Compliance Issues
Such problems can result in enforcement measures in case they are not proactively dealt with.
The United Arab Emirates has actively fought 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.This article describes the goAML system, its registration requirements, and compliance procedures in the United Arab Emirates (UAE).
The goAML system was developed by the United Nations Office on Drugs and Crime (UNODC) to combat 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 large number of financial intelligence units around the world, while the UAE is the first in the Gulf to implement this modern system.
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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.
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:
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 states that every entity must 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.
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.
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.
| Registration Type | Deadline |
| Existing Companies | 30 April 2021 |
| New Companies | Within a reasonable time after constitution |
The deadline for the registration of existing companies on the goAML portal was 30 April 2021. The registration for new companies should, however, be performed within a reasonable time after their constitution.
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. |
| Penalty Type | Details |
|---|---|
| Standard Fine Range | AED 50,000 to AED 1 million |
| Escalated Fine (in severe cases) | Can be doubled up to AED 5 million |
| Legal Basis | As per Cabinet Resolution No. 16 of 2021 |
| Assessment Authority | Supreme Committee for Combating Money Laundering, Financing of Terrorism and Illegal Organisations |
It is important to understand the significance of completing the post-registration procedures and measures to avoid the fines set by 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, Financing of Terrorism and Illegal Organisations.
Furthermore, failing to report suspicious transactions could make the entity liable for further legal liabilities.
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 for 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 complies; reach out today for professional guidance in this respect.
The registration factor includes:
Registering with goAML is a crucial compliance requirement under the UAE AML regulations.
It allows tracking suspicious transactions effectively, contributes to national security goals, and helps stay in line with international AML requirements.
Timely registration, proper reporting, and ongoing compliance have become important in the business, with the recent amendments in the law putting additional regulatory pressures on businesses.
Those companies that make the appropriate investments in the AML compliance solutions, qualified AML compliance officers, and structured reporting systems are in a better position to safely and sustainably operate in the UAE.