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3.4. How to Submit an STR and Other Report Types

يسري تنفيذه من تاريخ 7/6/2021

LFIs are required to submit suspicious transaction and activity reports directly to the FIU using the “goAML” portal, and registration in the system is mandatory for all entities under CBUAE’s supervision. According to the Guidelines on Anti-Money Laundering and Combating the Financing of Terrorism and Illicit Organizations for Financial Institutions, the FIU has launched the goAML system for the purposes of facilitating the filing of STRs, SARs, and other report types by all LFIs. LFIs should register themselves on the goAML system by following the “GoAML Registration Guide” and maintaining their registration in an “active” status. An entity’s Compliance Officer or MLRO can register as the user of the system. GoAML provides a secure link from each LFI to the FIU through their respective supervisory authorities. The system also has an .xml schema for filing batches of STRs. All newly licensed LFIs should register themselves immediately after obtaining their financial services license. Failure to register within the goAML system may result in a breach of the LFI’s AML/CFT obligations and will be dealt with in accordance with the prevailing legal provisions related to non-compliance.

According to the “goAML XML Submission Guide,” the goAML system reflects multiple mandatory fields, business rules, and various binding scenarios. Combined, the system only accepts reports that pass through the minimum requirements set by the FIU. Mandatory fields for submitting a report in the goAML system are noted below:

1.Select the Report Type [4.2.1 GoAML XML Submission Guide]: A Compliance Officer or MLRO should select a report type and populate all available details in the ‘Report Cover’ as depicted below:
 
  • Reporting Entity ID - Entity name as per the registration (auto-generated)
  • Internal STR/SAR # - Internal STR/SAR number
  • Submission Date* - Date of escalating the Report to the FIU (auto-generated)
  • Description/Summary of the Report* - Brief overview for the suspicion/reason for submitting this report to the FIU. This field is only mandatory for STR and SAR report types
  • Reporting Entity Branch - Branch where the main subject(s) of the report were identified
  • Report Type* - Report type relevant to the suspicion/reason for submission to the FIU
  • FIU Reference - Only applicable in the case of AIF/RFI/ AIFT/RFIT type reports. Provide the corresponding case number as specified in the Message Board communication sent by the FIU
  • Action Taken by Reporting Entity* - The action(s) taken by the reporting entity post- identifying the reason for suspicion/submission

 

2.MLRO Details [4.2.2 GoAML XML Registration Guide]: This section of the report includes details on the Compliance Officer, MLRO, or individual filing the report, which is automatically populated using the details provided during the registration phase.6
3.Location of the Incident [4.2.3 GoAML XML Registration Guide]: The location of the incident requires the location where the suspicious incident/transaction originated from. This is mandatory for STR and SAR report types.
4.Reason for Reporting [4.2.4 GoAML XML Registration Guide]: The LFI is expected to select the most appropriate reason for reporting available from the menu selection provided. If necessary, more than one reason may also be provided. It is imperative that the correct Reason for Reporting (“RFR”) is chosen for STRs or SARs submitted in the goAML system.7
5.Transactions [4.2.5 GoAML XML Registration Guide]: If the reported activity involves transaction(s), the LFI should populate the following transaction details:
 
  • Transaction Ref. Number* - Kindly use the auto-generate button to generate a unique identification number if the LFI is not a Bank/Exchange House
  • Reporting Entity Internal Reference Number*- Reporting entity's internal transaction reference number
  • Type of Transaction* - The mode used to conduct the transaction being reported
  • Late Deposit - Does this transaction account as a late deposit? (Yes or No)
  • Total Suspected Amount* (AED) - Suspected amount in AED
  • Date* - Date when transaction was initiated
  • Indemnified for Repatriation* - If the reporting entity has received an indemnity for repatriation
  • Transaction Executed by (Staff Name) - Name of the staff member who executed the transaction
  • Authorizer - Name of the staff member responsible for authorizing the transaction
  • Branch executing the transaction* - Branch where the transaction was executed
  • Date of receipt for recall request* (that field will only show if ‘Yes’ was selected for Indemnified for Repatriation) - The date when the reporting entity received the fund recall request
  • Purpose of the Transaction* - Purpose for executing the transaction
  • Transactions Comments - Comments (if any)
 
6.Transaction Type, From Type / To Type, My Client / Not My Client, Foreign Currency, Conductor, [4.2.5.1-4.2.5.5 GoAML XML Registration Guide]: Additional transaction details should be added according to the transaction type; transaction type (to/from) (i.e., my client, not my client); and foreign currency type (if applicable); and the amount. These fields should be populated by the LFI according to the GoAML XML Registration Guide’s instructions. Please refer to Party Type: Person (below) to populate information on the conductor of the transaction for 4.2.5.6.
7.Phone, Address, Identification, Email, and Employer Address and Employer Phone [4.2.5.7-4.2.5.11 GoAML XML Registration Guide]: These fields should be populated by the LFI according to the GoAML XML Registration Guide’s instructions.
8.Party Type [4.2.5.12 GoAML XML Registration Guide]: The Party Type’ refers to the initiating source (source of funds) and beneficiary/destination party in relation to the report being filed. The initiating source and beneficiary/destination party can be either a Person, Account, or Entity.
 
 •Party Type: Person [4.2.5.6, 4.2.5.13 GoAML XML Registration Guide]: Where the subject initiating or receiving the transaction is a person, clicking the ‘Person’ radio button will generate the following form and fields.
 
  • Title - e.g., Mr./Mrs./Dr.
  • Prefix - Prefix Name e.g., Von, Jr.
  • First Name* - First name of the person
  • Middle Name - Middle name of the person
  • Last Name* - Last name of the person
  • Gender - Male / Female
  • Birth Date - Date of birth of the subject person
  • Birthplace - Location where the person was born
  • Mother’s Name - Name of the person’s mother (if available)
  • Alias - A known alias for the person (if applicable)
  • Emirates ID - Emirates ID number; input the number without using any spaces/hyphens
  • Nationality 1 - First nationality of the person
  • Nationality 2 - Second nationality of the person
  • Nationality 3 - Third nationality of the person
  • ID Number - ID number; input the number without using any spaces/hyphens
  • Tax Number - Tax number for outside UAE without hyphens/spaces (e.g., FATCA number for US citizens)
  • Residence - Country of residence
  • Occupation - Known occupation of the subject
  • Employer Name - Name of the person’s current employer
  • PEP (Y/ N) - Specify if the person is a politically exposed person. Input “Y” or “N” accordingly
  • Source of funds - Primary source of funds used for the reported transaction
  • Passport* - Select if the passport details are available (Y/N)
  • Passport Number* - Input the passport number without any spaces/hyphens only in the absence of an Emirates ID
  • Passport Country* - Country of the passport provided
  • Deceased - Is the person deceased? (Y/N)
  • Date of Death - Date when the person died (applicable only if “Y” was provided in the ‘Deceased’ field)

 

 •Party Type: Account [4.2.5.14 GoAML XML Registration Guide]: If the transaction was initiated or received through an Account, clicking the ‘Account’ radio button will generate the following form and fields:

 

  • Account Number* - Account number without any spaces/ hyphens
  • Status Code (is mandatory for My Client) - Account status when transaction was initiated
  • Institution Name - Name of the institution where the account was created
  • UBO* - Who is the beneficial owner of the account?
  • Non-Banking Institution - Is the mentioned account held in a bank or otherwise (Y/N)
  • Client Number - Client Number as per reporting entity’s records
  • Account Type - Drop-down menu for type of account
  • Currency Code - Currency of the account
  • I BAN - I BAN as per standard format (no spaces/hyphens)
  • Opened* - Date of account opening
  • Closed - Date of account closure
  • Balance* (Y/N) - Input "Y" or "N” on whether there is a credit / debit in the account
  • Balance (if the ‘Yes’ radio button is selected (above)) - The current balance of the account in AED
  • Date of balance - Date when the balance was recorded
 
 •Please note that LFIs should also add a ‘Signatory(ies)’ form for reports involving accounts that are classified as ‘My Client.’ When the accountholder is a person, the LFI is required to enter all involved signatories. If the accountholder is an entity, the LFI is required to populate the entity details. For instances where an account has multiple signatories, all of the signatory details need to be captured in the goAML system.
 •Party Type: [4.2.5.15 GoAML XML Registration Guide]: If the transaction was initiated through an Entity, clicking the 'Entity radio button will generate the following form and fields.

 

  • Name* - Legal name as per documentation
  • Commercial Name - Commercial name as per documentation
  • Business Activity - Business activity of entity (drop-down)
  • Licensing Authority - Regulatory authority responsible for licensing the entity
  • Trade License Number Authority
  • Place of incorporation - Specify the city (Emirate in case of a UAE entity)
  • Establishment Date - Date when entity was established
  • Incorporation Country - Country where the entity was incorporated (drop-down)
  • Email - Registered email for the entity (if any)
  • Website - Website for the entity (if any)
  • Tax Number - Tax number for outside UAE without hyphens/spaces (e.g., FATCA number for US citizens)
  • Comments - Comments (if any)
  • PEP (Y/ N) - Specify if the person is a politically exposed person. Input "Y" or "N" accordingly
  • Latest date of trade license issuance/renewal - Date of trade license issuance/renewal
  • Latest date of trade license issuance/renewal - Date of trade license issuance/renewal
  • **Phones, Addresses, and Controlling Persons/Beneficial Owners can also be added. Addresses and Controlling Persons/Beneficial Owners section are mandatory only when the entity is classified as ‘My Client.’

 

9.Involved Parties [4.2.5.16 GoAML XML Registration Guide]: If there are multiple parties involved in the reported activity, the ‘Involved Parties’ form should be populated with the following fields.
 
  • Role* - Nature of association with the transaction
  • Funds Code* - The type of funds
  • Country* - Country of the involved party
  • Significance - Rate the significance of the concerned subject from 0 - 10 (0 being the lowest and 10 being the highest score
  • Funds comment - Comments on use of funds (if any)
  • Comments - Comments (if any)
  • **Foreign Currency can also be added

 

10.Good and Services [4.2.5.17 GoAML XML Registration Guide]: This section corresponds to transactions involving the exchange of goods and services.

 

  • Item Type* - The type of item (e.g., Vehicle)
  • Description - Description of the item (e.g., Luxury Car)
  • Manufacturer - Item maker (e.g., if the item is a car - BMW)
  • Presently Registered To - Name of current owner
  • Previously Registered To - Name of previous owner
  • Status Code - Stats code (e.g., Bought, Hired)
  • Estimated Value - Estimated value of the item
  • Currency Code - Used to report service conducted in foreign currency
  • Disposed Value - Effective value for property transfer (value must be in AED)
  • Size UOM - Unit of measurement (e.g. square meters)
  • Size - Size of the property
  • Registration Number - Official registration number (e.g., Car VIN Number)
  • Registration Date - Official registration date (in MM/DD/ YYYY format)
  • Identification Number - Any number that can identify the item (e.g., Car Plate Number)
  • Comments - If applicable
  • **Addresses can be added

 

11.Activity [4.2.6 GoAML XML Registration Guide]: If the report does not contain any transaction(s), then the activity details may be captured in the report. The activity details should include the significance of a concerned subject (scale of 0-10), the reason for reporting the party, and any comments. The ‘Activity’ tab will be shown only in the case the reporting entity is submitting an “SAR”, “RFI without transaction(s)” or an “AIF without transaction(s)” based report file.
 

Upon completion of all the mandatory fields (noted above) and submission of the report in the goAML system, the report will be provided to the FIU. It is mandatory for the LFI’s filer to attach supplemental documents to accompany the submission—including but not limited to—Know Your Customer (“KYC”) documentation, copies of identification documentation, account opening forms, transaction receipts, financial statements, and other documents relevant to the investigation. In the instance that the LFI conducted due diligence or internal investigations, the corresponding documents must also be attached. This will assist the FIU in reviewing the report with all the appropriate documentation to support its review and analysis.

6 The UAE FIU has noted that there have been instances of reports being received whereby upon review, the LFI’s MLRO and related team members’ contact details were not updated in the goAML system, which included email addresses and phone numbers. Keeping contact information updated helps with the two-way communication between LFIs and the FIU while helping to shorten the turnaround time of report analysis. It also enhances the ability of the FIU to analyze and subsequently process reports in a timely manner. The contact information should be kept updated at all times.
7 The UAE FIU has noted that in some cases LFIs file reports while choosing RFRs that, upon closer examination, are not linked to the actual suspicions of the report. As an example, reports have been received with RFRs related to the financing of terrorism and illegal organisations with no evidence of any activity connected to the financing of terrorism and illegal organisations. Selecting incorrect RFRs hinders the FIU’s analysis, and the LFI should expect multiple requests by the FIU for further clarification in these cases. LFIs should be prudent and diligent when choosing RFRs and submitting reports to the UAE FIU. RFRs should be chosen correctly and in relation to the actual suspicions of the STR or SAR being submitted.