United Arab Emirates (UAE), a global investment and tourism hub is one of the important economies in the Middle East and the world. While the UAE attracts investment from around the world, the country’s wealth also makes it a huge target for criminals seeking to exploit its financial system.
Since 2001, the UAE Government (UAEG) has taken initiatives to better monitor cash movements via the UAE’s financial system and to collaborate with international efforts to combat terrorist financing. The country maintains a strong Anti-Money Laundering (AML) system in an effort to protect against the possibility of money laundering and terrorist financing.
The UAE government committed to meeting the requirements of its Financial Action Task Force (FATF’s) action plan by improving its AML/CFT framework and clamping down on organizations that fail to meet their compliance obligations.
This increased regulatory scrutiny means that companies operating in the United Arab Emirates need to understand their country’s AML/CFT environment, manage risks, and adapt internal procedures if they are to comply. So, in this blog, ‘What is AML registration? Which companies should do AML Registration? We’ll discuss AML compliance in UAE, the firms that need to be registered with the system, the steps and documentation required, etc.
What is goAML in UAE?
The goAML is a software application used by the United Arab Emirates Financial Intelligence Unit (FIU) to combat money laundering and terrorist financing. The fully integrated system was developed by the United Nations Office on Drugs and Crime (UNODC) and used to quickly and efficiently receive and distribute Suspicious Transaction Reports ( STRs).
Who Should Register With the goAML System?
All the following firms must register on the UAE FIU’s goAML Portal:
- Financial Institution
- Virtual Asset Service Providers (VASPs)
- Designated Non-Financial Businesses and Professions (DNFBPs)
-Dealers in Stones & Precious Metals
-Real Estate Agents and Brokers
-Trust and Corporate Service Providers
-Lawyers, Notaries, and independent legal professionals
-Independent Accountants and Auditors
Documents Required for goAML Registration
These are the documents required for goAML registration:
- The organization’s Authorisation Letter in favor of the designated AML/CFT Compliance Officer
- A copy of the passport/resident visa/Emirates ID of the Compliance Officer
- A copy of the organization’s commercial trade license
Along with the above documents, the organization must also download and submit the ‘Google Authenticator’ application on the mobile of the registered contact number.
UAE goAML Registration Type
The Financial Intelligence Unit of the UAE prescribes three types of goAML registration options available through the goAML Portal.
• Reporting Entity
• Stakeholder
• Supervisory Body
Financial Institutions (FIs), VASPs, and DNFBPs are registered under the category of “Reporting Entities” on the goAML portal.
How to Register On the goAML Portal?
The goAML registration is a two-stage process:
STEP 1 – Register in the Service Access Control Manager (SACM) system of the UAE FIU to get the username and the Secret Key for accessing Google Authenticator.
STEP 2 – Registration on the UAE FIU’s goAML Portal, furnishing information about the organization and the Compliance Officer.
Why Should You Register On goAML Portal?
The Financial Intelligence Unit ( FIU) of UAE uses the goAML to collect information and data about suspicious transactions involving money laundering and terrorism financing.
Under the Federal Decree Law No (20) of 2018 and Article 20(2) of Cabinet Decision No (10) of 2019, it is mandatory to have procedures in place to report suspicious transactions to manage anti-money laundering (AML) in the United Arab Emirates. This system helps companies to assist authorities in identifying criminal and suspicious activities.
The integrated platform is used to file reports including :
- Suspicious Activity Report (SAR)
To report any suspicious transactions involving ML/FT/PF while building business contacts or transactions.
- Suspicious Transaction Report (STR)
To report any suspicious activity or attempted/unexecuted transaction related to Money Laundering and Financing of Terrorism.
- Dealers in Precious Metals and Stones Report (DPMSR)
To report transactions by the Dealers in Precious Metals and Stones, equal to or exceeding AED 55,000, in cash or wire transfer, along with identification documents.
- Real Estate Activity Report (REAR)
Reporting, by lawyers and real estate brokers/agents, of purchase and sale of Freehold real estate above specified amount involving cash or virtual.
- Fund Freeze Report (FFR)
For reporting any freezing measure and prohibition to provide funds/services, related to confirmed matches’ with the Sanctions List.
- Partial Name Match Report (PNMR)
For reporting any potential match with the sanctions List.
- High-Risk Country Transaction Report (HRC)
To report transactions related to high-risk countries as defined by the UAE National Anti-Money Laundering and Combatting Financing of Terrorism and Financing of Illegal Organizations Committee (NAMLCFTC).
- High-Risk Country Activity Report (HRCA)
To report activities related to high-risk countries as defined by the UAE National Anti Money Laundering and Combatting Financing of Terrorism and Financing of Illegal Organizations Committee (NAMLCFTC).
What If a business in UAE Fails To Register in goAML?
All financial institutions, VASPs, and DNFBPs are required to complete registration on the UAE FIU’s goAML Portal. The absence of registration on the goAML Portal indicates a failure on the part of the regulated organization to establish essential procedures for identifying and reporting suspicious transactions linked to money laundering or terrorism financing. Consequently, the failure to register on the goAML portal constitutes a breach of the AML/CFT regulations in the UAE, resulting in potential administrative penalties ranging from AED 50,000 to AED 5,000,000.
An overview checklist of core AML regulations in UAE
Here is a list outlining the fundamental AML/CFT responsibilities assigned to DNFBPs In the UAE:
- Have you registered with the goAML Portal?
- Do you have a competent AML/CFT Compliance Officer in charge of your AML compliance?
- Have you discovered and evaluated your company’s exposure to ML/FT risks?
- Are your AML/CFT policies, processes, and controls effective and in line with AML/CFT regulations and Enterprise Wide Risk Assessment (EWRA)?
- Have you assessed your clients’ risk using relevant ML/FT risk factors?
- Do you retain all of your AML/CFT records for at least five years?
