In the United Arab Emirates (UAE), the goAML platform facilitates the seamless processing, analysis, and sharing of Suspicious Transaction Reports (STRs). Developed by the UNODC, goAML is an advanced software solution designed to combat global challenges related to money laundering. The UAE was among the earliest adopters of the goAML system in the Gulf region, demonstrating its commitment to international cooperation and financial transparency.
Key Features of the goAML System
Advanced Reporting and Data Collection and Analysis
FIU can collect and analyze data concerning suspicious monetary transactions using goAML. The collected information could aid in effective, timely, and accurate decision-making processes when making an investigation.
- Strategic and Compliance Enforcement Reporting System (SCERS) covers and detects the Money Laundering (ML) and Terrorism Financing (TF) exposure at account and transaction levels.
- The goAML system receives a steady flow of all transactions or activities that can show ML/TF from the DNFBPs and financial institutions’ goAML systems.
- Data aggregation in the goAML system allows for the identification of illegal patterns by financial institutions and DNFBPs.
GoAML System Roles:
The goAML system is meant to:
- Enhance identification and reporting of suspicious activities.
- Enhance international financial compliance.
- Sustain the UAE’s financial system integrity.
- Protect the nation’s economy from the threats of ML/TF activities. From these, UAE is in a better position in the world as a financial center with transparent governance.
Who should register to the goAML Portal?
According to Federal Decree-Law No. (20) of 2018 and Cabinet Decision No. (10) of 2019, certain individuals on the goAML Portal must be registered. Among others, the following need to be registered:
- Financial Organization
- Trading Houses
- Other companies rendering any financial services
- Banks
- Professionals and Businesses That Are Designated Non-Financial: Real Estate brokers and agents
- Dealers in gemstones and precious metals
- Auditors and accountants
- Legal practitioners: Lawyers and Notaries Elsewhere
- Business service providers, and Trusts
- Providers of Virtual Assets Services
- Cryptocurrency exchanges
- Companies dealing with virtual assets
Non-registration offends the UAE law hence imposition of penalties and other consequences.
Compulsory Registration for DNFBPs
Every DNFBP must register with the goAML program. This allows these entities to file STRs or SARs should they consider a transaction suspicious. According to Federal Decree-Law No. (20) of 2018, there are internal mechanisms that are required within the DNFBPs to monitor compliance and identify suspicious transactions. Administrative penalties and heavy monetary fines were imposed by the Ministry of Economy, as well as judicial ones, in the case of non-compliance.
Setting Up goAML Portal Registration
- Business registration must occur before the cut-off date of April 30, 2021.
- Starting businesses: Registration must be done right after the business is set up.
Documents Required For goAML Account Registration
The following documentation is needed in order to successfully finish the goAML registration process:
- A letter of authorization from the company
- Passports, Emirates ID, and Resident Visa copies for the Compliance Officer
- Trade License (for commercial entities)
- Details of the Google Authenticator app for safely accessing the account
Steps for goAML registration in the UAE
All institutions dealing with financial transactions are under a mandatory registration process for the goAML Portal such as VASPs (Virtual Asset Service Providers), and DNFBPs (Designated Non-Financial Businesses and Professions). The registration is categorized into two stages, and each stage will guide the institution to adhere to anti-money laundering regulations.
Stage 1: Registration on the SACM System (SACM is referred to as “Service Access Control Manager”)
- The first step is to sign up in the SACM system, which will issue a username and secret key used for Google Authenticator.
Open SACM Portal: – Go to SACM Registration. Fill up the online form with the following considerations:
- Fill in all mandatory fields marked with (*).
- Select “Reporting Entity” under “Registration Type”.
- Select an appropriate Supervisory Authority.
- Enter your Trade License number in “ID Number/Reg. No.”.
- Give the correct phone no. and e-mail ID to receive the OTPs.
Upload Required Documents: – Single PDF file based on all of the documents such as Commercial/Trade License, Authorization Letter, Copy of Passport Copy, Residence Visa Emirates ID, with their email IDs (goaml@uaefiu.gov.ae) (no-reply.sacm@uaefiu.gov.ae)
Obtain OTP and Secret Key: – You will obtain an email containing an OTP and a link to acquire your username and secret key after submission. The OTP received is active for 24 hours.
Set Up Google Authenticator
- Download the Google Authenticator app.
- Add an account with details enclosed in the email.
Stage 2: Registration on the GoAML Portal
Registration of your organization on the GoAML Portal and detail filling up
- Login to goAML Portal: – Use the goAML Portal. Now login by using the username together with a Google Authenticator code that will be a password.
- Organization Registration: – click on “Register as a New Organization”.
- Complete all the mandatory fields marked with (*).
- Provide correct organizational details and Compliance Officer information.
Wait for Approval
After submitting, your registration will be assessed by the concerned Supervisory Authority. In case of approval, a unique ID for your organization will be issued.
Importance of GoAML Registration
Below are the consequences of failing to register on the goAML portal:
- Judicial as well as Financial Punishment: –In the UAE you will be contravening AML laws. Fines are between AED 50,000 and AED 1 million, and repeat offenses can be struck with AED 5 million fines.
- Operational Challenges: –The goAML system has set up procedures whereby clients will not be able to register if they have not submitted certain reports and therefore have no legal obligations to abide by.
- Reputational Risk: –Non-compliance hurts the credibility of businesses and professionals alike and affects their relationship with clients and with regulators.
Report Types Filed using the GoAML Portal
Using the GoAML system, various templates have been created that enable users to file reports on every suspicious activity allowing for the activities to be monitored on file.
| Type of Report | Purpose | Deadline |
| Suspicious Transaction Report (STR) | Withdrawals made that are suspected to be tied with ML/TF are reported. | Upon suspicion of such transactions, please report immediately. |
| Suspicious Activity Report (SAR) | Transacted that have suspicious ML/TF activity are reported. | As soon as the activity has been detected, such a report should be made. |
| DPMS Report (DPMSR) | Reports expenditures of high value associated with gold and silver. | A report needs to be filled within two weeks after the transaction. |
| High-Risk Country Report (HRC) | Transactions associated with high-risk countries are reported. | Such a report needs to be filed during negotiations with such high-risk jurisdictions. |
| Report on Real Estate Activity (REAR) | Reports in regards to real estate deals that were paid cash or virtual assets. | Such a report should be made as soon as those transactions take place. |
| Fund Freeze Report (FFR) | Reports that describe the freezing of assets to adhere to sanctions. | This sort of report needs to be made after the funds have been frozen. |
| Report on Partial Name Matching (PNMR) | Slight matches with sanctioned persons or businesses are reported. | Report should be made immediately after a partial match of name is found during due diligence. |
Penalties for Violating Rules
A breach in goAML registration may lead to:
- Monetary Sanctions: – An initial violation of the goAML registration may lead to fines of AED 50,000-1 million. Repeated violation increases fines to AED 5 million.
- Legal Liabilities: – Increased risks of unsuspicious transaction reporting to be sanctioned with the legal form of criminal charges on the entities that were involved.
The United Arab Emirates (UAE) utilizes the goAML system to monitor money laundering activities within its financial institutions. Additionally, registration enhances reporting capabilities, transparency, and compliance across the entire financial ecosystem. Businesses are encouraged to engage the expertise of reputable Business consultants in UAE to efficiently meet Anti-Money Laundering (AML) requirements and ensure full compliance with regulatory standards. For professional assistance, please contact us—we would be pleased to support you.
Frequently Asked Questions on goAML Registration in the UAE
- What is the GoAML registration in UAE? Combating money laundering (ML) is more effective with goAML registration because registered organizations are able to identify and report suspicious transactions by submitting a suspicious activity report (SAR). The GoAML registration will assist in furthering the objectives of laws and regulations dealing with the United Arab Emirates.
- Which entities are required to register on the goAML portal? Registration under the law of the UAE is required for the following persons: financial institutions, real estate agents, dealers in precious metals, legal professionals, and providers of services related to virtual assets.
- What is the deadline for registering in GoAML? For companies that were operating before April 30, 2021, the deadline was the date of registration, whereas recently incorporated companies were obliged to register immediately after formation.
- What documents are needed for GoAML registration?
- An authorization letter;
- Compliance officer’s passport/emirates ID and visa;
- Business trade license,
- Details of a google authenticator app for easy system access.
5. What is the outcome if a goAML is not registered?
The Penalty is as follows:
- Monetary Penalty between AED 50,000 to AED 1 million.
- The penalty may go up to AED 5 million in case of repeated offenses.
