goAML: Anti Money Laundering RegistrationIn UAE

Failure to complete your registration on the goAML system may lead to significant penalties enforced by the Ministry of Economy. While the Ministry of Economy initially set April 30, 2021, as the deadline for registration, they are currently still accepting registrations.

Anti Money Laundering and Counter Terrorism Financing

The United Arab Emirates (UAE) has been diligently working on strategies to combat illegal funding of organizations and money laundering activities, all while adhering to international standards set by the Financial Action Task Force (FATF). To accomplish this mission, the UAE established the Financial Intelligence Unit (FIU) under the Central Bank of the UAE (CBUAE). Consequently, the FIU’s primary role is to regulate and monitor entities, both directly and indirectly involved in facilitating such activities within the country’s economy.

As part of this initiative, Federal Decree-law no. 20 of 2018 on Money Laundering, Financing Terrorism, and Illegal Organizations was introduced. This new law superseded the previously issued Federal Decree-Law no. 4 of 2002.

It is crucial to emphasize that all regulated entities, including financial institutions (FIs) and Designated Non-Financial Businesses and Professionals (DNFBPs), are required to implement robust Anti-Money Laundering and Counter-Terrorist Financing (AML-CTF) policies and controls throughout their operations. Equally important is the need to thoroughly document these measures.

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AML-CTF Framework

What Is Money Laundering?

Money laundering comprises three fundamental phases, and it is imperative for all regulated entities to vigilantly identify specific indicators that may raise suspicions, necessitating monitoring and further investigation.

As articulated by the Ministry of Economy, money laundering is defined as any financial or banking transaction devised to obfuscate or disguise the origin of unlawfully acquired funds, with the intent to evade their detection within the financial and banking systems, subsequently reintegrating them into the financial realm.

These three phases are as follows:

  1. Placement: Involves the act of introducing illicitly obtained funds into the formal financial systems.

  2. Layering: Entails a series of complex financial transactions aimed at concealing the illicit origin of the proceeds, often involving intricate and convoluted financial maneuvers.

  3. Integration: Encompasses the creation of a facade of legitimate origin for the illicit proceeds, thereby rendering them seemingly legal within the financial framework.

 

Money Laundering Offenses and Definitions

The Decree-Law, in its provisions, defines an individual culpable of a money-laundering offense as someone who is fully aware that the money in question originates from a criminal act. With this understanding, they intentionally engage in one of the following actions:

  1. Transmitting or transporting proceeds of criminal activity with the explicit intent to conceal their illicit source.
  2. Concealing or camouflaging the true nature, origin, location, method of disposition, movement, or rights associated with any proceeds or their ownership.
  3. Acquiring, possessing, or utilizing such illicit proceeds.
  4. Assisting the perpetrator of the underlying criminal offense in evading punishment.

These definitions and phases serve as the cornerstone for critical efforts to combat and deter money laundering, ultimately ensuring the integrity and transparency of financial systems.

Regulated Entities For goAML

Financial Institutions (FIs) and Designated Non-Financial Businesses and Professionals (DNFBPs) registered in the United Arab Emirates (UAE) bear specific obligations that must be diligently adhered to in order to ensure compliance with the prevailing laws and regulations. Failure to meet these obligations can result in legal violations and associated penalties.

First and foremost, it is imperative for these entities to complete the registration process on the goAML system. The Financial Intelligence Unit (FIU) has developed the GoAML System to streamline the reporting of suspicious transactions and activities, facilitating a more convenient process for regulated entities.

Furthermore, the following key steps must be taken:

  1. Appointment of an Independent and Qualified Compliance Officer: Each entity is required to designate a compliance officer who possesses the requisite qualifications and independence to oversee compliance matters effectively.

  2. Development and Implementation of Robust Internal Controls, Policies, and Procedures: This entails the formulation and enactment of comprehensive internal controls, policies, and procedures. These should encompass the following areas:

    • Customer and Employee Due Diligence, often referred to as Know Your Customer (KYC) and Know Your Employee (KYE).
    • Screening of customers against sanction lists.
    • Ongoing monitoring and training programs.
    • Conducting thorough customer due diligence.
    • Implementing risk management procedures.
    • Reporting of suspicious transactions.
    • Enrollment in an automated system for reporting sanctions lists.

Policies and Procedures

The Ministry of Economy is set to carry out regular inspections of all DNFBPs with the aim of evaluating the extent to which these obligations are being met. In pursuit of this goal, measures will be taken to ensure compliance, with any violations subject to penalties as stipulated by the regulations.

These policies and procedures can be categorized into several key areas:

  • The Ministry of Economy plans to conduct regular inspections of all DNFBPs to assess their compliance with obligations. To achieve this, various measures will be implemented to ensure adherence, with penalties for violations as per regulations.
  • These policies and procedures can be categorized into several key areas. First, there are the Customer Acceptance Policies and Risk Assessment/Categorization, which involve setting clear criteria for customer acceptance and risk assessment.
  • Next, the Know Your Customer Policy involves implementing due diligence measures for customer identification and verification. Additionally, Customer Screening Against Sanction Lists entails regularly screening customers against sanction lists to identify potential risks.
  • Furthermore, the Monitoring Policy and Suspicious Transaction Reporting are vital for ongoing monitoring and reporting of suspicious transactions. The Know Your Employee Policy is also crucial to gain a comprehensive understanding of employees’ backgrounds and roles.
  • Moreover, the Staff Training Policy plays a pivotal role, involving the conduct of regular training sessions to enhance awareness and understanding of compliance measures.
  • Lastly, there’s a need for a Compliance Officer and Independent Internal Audits. This involves appointing a compliance officer and conducting independent internal audits to assess and verify compliance efforts.
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FAQ

The UNODC has developed the ‘goAML’ platform to combat organized crime, requiring all financial entities and Designated Non-Financial Businesses or Professions to register. This will aid UAE’s Financial Intelligence Unit in preventing money laundering and financing terrorism.

To submit suspicious transaction reports (STRs) to the goAML system, you must register. The goAML system is an internationally recognized electronic method for collecting and analyzing financial and non-financial data to prevent money laundering and combat terrorism financing. There are two registration stages: the goAML portal’s protection system (SACM) and the goAML system.

Regarding Anti Money Laundering (AML) compliance, we will conduct initial evaluations of your business to ensure that you are fully prepared to meet the requirements for the goAML Declaration process. Our aim is to assist you and your business in achieving AML system compliance in a thorough and professional manner. We are dedicated to helping you navigate this process efficiently and effectively.or them.

  1. Visit https://services.uaefiu.gov.ae/ Systems >> GOAML
  2. Login using username received from no-reply.sacm@uaefiu.gov.ae &Google Authenticator Passcode as the password
  3. Login using the username and password created at the time of registering on goAML Portal

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

The Ministry of Economy has stipulated heavy penalties for organizations that 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 Subject to the Supervision of the Ministry of Justice and the Ministry of Economy.

UNODC is the United Nations Office on Drugs and Crime. You can reach UNODC at https://www.unodc.org/

goAML is a communication medium between the reporting entity and the Financial Intelligence Unit (FIU). All the suspicion reports and reporting of designated transactions prescribed under AML/CFT regulations will be reported via the goAML Portal. So to submit these reports, a reporting entity shall initially have to register with the goAML.