goAML System: Anti Money Laundering Registration UAE

Failure to register on goAML may result in severe penalties invoked by the Ministry of Economy.
According to the Ministry of Economy, last date to register in the goAML system was April 30, 2021. However, registrations are still being accepted by the MoE.

(As per UAE Misinstry of Economy)

About goAML

UAE contributes to global anti money laundering efforts and combating financing of

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Deadline for the goAML

According to the Ministry of Economy, last date to register in the goAML system was April 30, 2021. However, registrations are still being accepted by the MoE.

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Determine if you likely to be a Designated Non-Financial Businesses and Professions (DNFBP)

Are you a real estate firm?

Your firm carries out transactions with customers involving the buying or selling of real property. For example, real estate brokers and agents.

Are you an auditing or accounting firm?

You provide professional services and assurance to third parties on the financial of them and/or their business.

or example, chartered accountants, accountants, auditors etc.

Are you a dealer of precious metals or stones?

You are involved in the production of precious metals or precious stones, an intermediate buyer or broker, precious stone cutter and polisher, precious metal refiners, and/or jewelry manufacturer who use precious metals and precious stones to retail sellers to the public or buyers and sellers in the secondary and scrap markets. These include gold, silver, platinum, diamonds etc.

For example, jewelry stores.

Are you a Trust or Company Service Provider?

You are involved in providing company establishment and / or business administration services to third parties.

For example, company or legal person set up / formation, providing 3rd party directorships, business administration, providing registered business address services etc.

Are you a legal consulting company (Except Lawyers and Notary Publics)?

If your company conducts legal consulting company only and is not pleaded in the judicial courts

Note: If you are registered with the Ministry of Justice, you do not have to register with the Ministry of Economy.

You are likely NOT a DNFBP.

Note: this is guidance and not legal advice, we recommend you obtain independent legal advice.

You are likely to be a DNFBP. To Register on goAML

Note: this is guidance and not legal advice, we recommend you obtain independent legal advice.

Declaration of Anti Money Laundering (goAML)

Terms & Conditions

Why register on goAML

Registration in the 'goAML' system, filing of suspicious transaction reports through it

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Fines

According to the Ministry of Economy, fines ranging from AED 50,000 to AED 1,000,000

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Anti-Money Laundering and Counter-Terrorist Financing

UAE has been working on its strategies to combat Illegal funding of organizations and money laundering activities and comply with standards of FATF (Financial Action Task Force). In its mission to achieve this objective, Financial Intelligence Unit (FIU) was established under CBUAE (Central bank of UAE) to regulate and monitor entities that are/ most likely to be impacted/involved directly or indirectly in aiding such activities in the economy.

In this effort, Federal Decree-law no. 20 of 2018 on Money Laundering and financing terrorism and illegal organizations was introduced, which revoked previously issued Federal Decree-Law no. 4 of 2002.

Therefore, it is important to note that all regulated entities, including financial institutions (FIs) and the Designated Non-Financial Businesses and Professionals (DNFBPs), must implement robust AML-CTF policies and controls within their activities and document them.

What is Money Laundering?

Money Laundering has three important phases; all regulated entities need to look for specific indicators that might hint towards an activity being suspicious and need monitoring/investigation.

As per the Ministry of economy, “Money laundering is defined as any financial or banking transaction aimed at concealing or changing the source of illegally obtained funds, bypassing it through the financial and banking system to make it appear as originating from legitimate sources, and then re-pumping and investing it illegally.”

The three phases include:

  1. Placement: Deposit Criminal proceeds into financial systems.
  2. Layering: Conceal the criminal origin of proceeds.
  3. Integration: Create an Apparent legal origin for criminal proceeds.

The Decree-Law defines a culprit of a money-laundering offence as any person who is aware that the money was originated from a felony or misdemeanour and intentionally commits one of the following acts:

  1. Transmitting or carrying proceeds of crime with intent to cover up or mask its illicit source
  2. Obscuring or cloaking the true nature, origin, location, way of disposition, movement or rights related to any proceeds or the ownership thereof
  3. Acquiring, possessing, or using such proceeds
  4. Aiding the offender of the predicate offence to escape penance.

Regulated Entities

  1. Financial Institutions (FIs)
  2. Designated Non-Financial Businesses and Professionals (DNFBPs)

All FIs and DNFBPs registered in UAE have certain obligations which need to be fulfilled to avoid violation of laws and regulations enforced, which include:

  1. Firstly, it is important to register on the goAML system.
    • FIU develops GoAML System to make suspicious transaction/activity reporting more convenient for the regulated entities.
  2. Secondly, appoint an independent and qualified Compliance officer.
  3. Develop strong internal controls, policies and procedures and implement including:
    • Know your Customers (KYC)/Employees
    • Sanctions Screening
    • Training and monitoring
    • Customer due diligence
    • Risk management procedures
  4. Reporting Suspicious transactions
  5. Register in the automatic system for reporting sanctions list

Ministry will conduct regular inspections of all DNFBPs to assess how these obligations are fulfilled and what measures are taken to ensure compliance and violations are penalized.

The policies and procedures that should be implemented can be categorized as follows:

  • Customer Acceptance policies and Risk Assessment/Categorisation
  • Know your Customer Policy: Due Diligence measures for identification and Verification
  • Customer Screening against Sanction lists
  • Monitoring Policy and Suspicious Transaction Reporting
  • Know your employee Policy
  • Staff Training Policy
  • Compliance officer and Independent Internal audits

As we know, Control and planning need to be conducted side by side, as planning without Control are unlikely to be effective and Control without proper planning.

So DNFBPs are expected to ensure that they plan appropriate controls and procedures to overcome the threat of money laundering or illegal financing activities and monitor them regularly to ensure they are implemented and updated whenever required.

Designated Non-Financial Businesses & Professions Of Entities Operating In The State

Pursuant to Article 3 Cabinet Decision No. (10) of 2019, a DNFBP is a firm that conducts one or more of the following activities

  • Real Estate agent involved in buying and selling of real estate.
  • Dealer of precious metals and stones.
  • Company Service Providers.
  • Auditors and accountants.
  • Legal Consultancy Firms (Except for Lawyers, and Notary Publics)

Above mentioned DNFBPs have two main requirements:

  • To Complete the registration on the ‘goAML’ system
  • And second to report suspicions of money laundering or terrorist financing is a criminal offence.

Failure to do any of the above will be considered by the MOEas a contravention of Article 20(2) of the Cabinet Decision No. (10) of 2019 for failing to put procedures in place for the reporting of the Suspicious Transactions.

What is goAML?

The United Nations Office on Drugs and Crime (UNODC) built the 'goAML' anti-money laundering reporting platform to combat organized crime. All financial entities and Designated Non-Financial Businesses or Professions must register on ‘goAML’. The platform will assist the UAE's Financial Intelligence Unit to hinder money laundering, financing of terrorism and other unlawful activities.

The goAML System Registration

The UAE's Ministry of Economy (MoE) has launched an awareness and monitoring campaign to enable registered Designated Non-Financial Business and Professions (DNFBPs) in the UAE to register with the Financial Intelligent Unit (goAML) system. It also encourages targeted groups to register in the system of the Committee on Goods Subject to Import and Export Control (Automatic Reporting System for Sanctions Lists), and to take action in accordance with both the provisions of Federal Law No 20 of 2018 on the fight against money laundering, terrorist financing, and the sponsorship of criminal organizations, as well as the legislation and related decision-making rules and regulations.

Why register on goAML

To submit suspicious transaction reports (STRs) to the goAML system, you must first register. goAML is internationally recognized electronic system for collecting and analyzing financial and non-financial data in order to prevent money laundering and combat the financing of terrorism You should be aware that there are two stages to the goAML registration stages.

  1. The registration stage in the goAML portal's protection system (SACM)
  2. The registration stage in the goAML system.

goAML Registration Deadline

According to the Ministry of Economy, last date to register in the goAML system was April 30, 2021. However, registrations are still being accepted by the MoE.

Money laundering punishment in UAE

The Ministry of Economy has stipulated heavy penalties for organizations who fail to comply with the Anti-Money Laundering (AML) and Combating Financing of Terrorism requirements by the due date. Violators of anti-money laundering or ultimate beneficial owner procedures may face administrative fines ranging from AED 50,000 to AED 1,000,000, according to the Ministry of Economy (MoE).

Cabinet Decision No. (16) of 2021 Regarding the Unified List of the Violations and Administrative Fines for the Said Violations of Measures to Combat Money Laundering and Terrorism Financing that are Subject to the Supervision of the Ministry of Justice and the Ministry of Economy.

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How to register in goAML System data

In relation with the Anti Money Laundering, we will Perform Preliminary Assessment your business in fulfilling and complying to the process, procedures, and submission of your goAML Declaration. We are here to help you and your business to comply with Anti Money Laundering system requirements in efficient and professional manners.

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