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  • 3. Procedures for the Reporting of Suspicious Transactions

    All customers and accounts should be subject to monitoring under a risk-based approach in order to identify potentially suspicious transactions, patterns, as well as behavior that is inconsistent with past behavior on the account or with the anticipated activity on the account as determined at onboarding. Alerts on such behavior are risk relevant indicators of potentially suspicious activity. Upon identifying unusual or potentially suspicious activity, an LFI’s employees must review and, as appropriate, escalate the activity for further investigation or immediate action.

    Although the process for reviewing unusual or potentially suspicious activity for further investigation or immediate action is not outlined in this guidance, LFIs should establish a process to investigate such activity, including developing policies and procedures that document the process for deciding whether to close the alert or to promptly report the transaction as suspicious and should include guidance on capturing detailed descriptions for the manner in which the alerts were either disposed of by reporting or closure of the alerts. For the purposes of this guidance, best practices are discussed once activity is determined to meet one or more of the regulatory definitions of suspicious activity and when an LFI decides to report such activity to the FIU by filing an STR, SAR, or other report type.

    • 3.1. Importance of Filing an STR and SAR

      The information generated from an STR, SAR, and other report type is important for identifying and combatting financial crime. First, the quality of STRs, SARs, and other report types is imperative for increasing the FIU’s analytical function to identify vulnerabilities and threats to the UAE financial system and develop an overall understanding of money laundering and the financing of terrorism and illegal organisations’ risks based on emerging trends and patterns. Relatedly, STRs, SARs, and other report types also assist law enforcement in detecting criminal actors and preventing the flow of illicit funds through the UAE financial system. Law enforcement uses the intelligence generated from STRs, SARs, and other report types to initiate and supplement money laundering or terrorist financing investigations and other criminal cases. As a result, it is critical that the information provided in all reports of suspicious activity be as accurate, timely, and complete as possible.

    • 3.2. Basic Structure of an STR or SAR

      The Compliance Officer or MLRO and other concerned employees responsible for using the goAML system must be aware of the different report types. As such, the LFI should select the correct report type when filing a report through the goAML system. The STR and SAR are the primary (or first instance) reports which must be used to report a new suspicion, whereas Additional Information File without Transactions (“AIF”) and Additional Information File with Transactions (“AIFT”) report types are supplementary reports which can be used to escalate additional information or transactions that correspond to a previously filed STR or SAR. When filing an AIF or AIFT, the LFI should input the Reference Number that corresponds to the STR or SAR.

       •STR: If, during the establishment or course of the customer relationship, or when conducting transactions on behalf of a customer or an occasional customer, an LFI suspects transactions are related to money laundering, related predicate offenses, or the financing of terrorism or illegal organisations, then the LFI should submit an STR to the FIU within the timelines established in this guidance.
       •SAR: If, during the establishment or course of the customer relationship, an LFI suspects any activity or an attempted transaction (i.e., a non-executed transaction) can be related to money laundering, related predicate offenses, or the financing of terrorism or illegal organisations, then the LFI should submit a SAR to the FIU within the timelines established in this guidance.
       •Additional Information File (“AIF”) without Transactions: Should the FIU require any further details while reviewing an STR or SAR, then the LFI that originally submitted the report may be solicited for further information by receiving an AIF request from the FIU through the Message Board. Should such a situation arise, the LFI is required to submit an AIF based report through the goAML platform. Please note that an AIF is a supplemental report that does not contain transactional details.
       •Additional Information File with Transactions (“AIFT”): Should the FIU require any further details including transactions while processing an STR or SAR, then the LFI that originally submitted the said report may be solicited for further information including transactions by receiving an AIFT request from the FIU through the Message Board. Should such a situation arise, then the LFI is required to submit an AIFT report through the goAML. Please note that an AIFT is a supplemental report that contains transactional details.
       •Request for Information (“RFI”) without Transactions: Should the FIU require further information from multiple LFIs rather than just the entity responsible for submitting the STR or SAR, then an RFI request will be sent out to the concerned LFIs through the goAML Message Board. Should such a situation arise, then the LFI is required to submit an RFI report through the goAML portal.
       •Request for Information with Transactions (“RFIT”): The ‘RFI with Transaction(s)’ report is similar to the structure of an RFI request, with the exception that this report type supports the use of transactions.
       •High Risk Country Transaction Report (“HRC”): If, during the establishment or course of the customer relationship, or when conducting transactions on behalf of a customer or a potential customer, an LFI identifies transactions related to high-risk countries as defined by the National Anti-Money Laundering and Combating the Financing of Terrorism and financing of Illegal Organizations Committee2, then the LFI should submit an HRC to the FIU. Such reported transaction(s) may only be executed three working days after reporting such to the FIU, and if the FIU does not object to conducting the transaction within the set period.
       •High Risk Country Activity Report (“HRCA”): If, during the establishment or course of the customer relationship, or when conducting an activity on behalf of a customer or a potential customer, a reporting entity identifies activities related to high-risk countries as defined by the National Anti- Money Laundering and Combating the Financing of Terrorism and financing of Illegal Organizations Committee3, then the entity should submit an HRC to the FIU. Such reported activity(ies) may only be executed three working days after reporting such to the FIU, and if the FIU does not object to conducting the activity within the set period.
       

      When all applicable information is collected, analyzed, and documented and the LFI decides that an STR or SAR is required, the information should be described in the narrative within an investigative narrative report template in a concise and chronological format. The LFI should divide the narrative into three sections: an introduction, a body, and a conclusion. The investigative narrative report template is considered as an addition to the goAML report (due to the potential text limitation within the “goAML description of the report” field).

       •Introduction
       
       The introductory paragraph should provide:
       
       •A brief statement addressing the purpose of the report with a general description of the known or alleged violation.
       •The name(s) of the subject against whom the report is filed.
       •Any linked/ previous STRs, SARs, or other reports, including the date of any STR(s) / SAR(s) filed (or other reports) previously on the suspect or related suspects and the reason why the previous STR(s) / SAR(s) (or other report) was filed.
       
       Additional Guidance:
       
       •Whether the activity is associated with any sanctioned countries or contained on government lists for individuals or organisations.
       •A summary of the “red flags” and suspicious patterns of activity that initiated the report. (This information should be provided either in the introduction or conclusion of the narrative).
       
       •Body
       
       The next paragraph or paragraphs of the narrative can provide all pertinent information documenting why the STR, SAR, or other report was filed and might include:
       
       •Details of parties facilitating the suspicious activity or transactions. If the subject is an entity, details of the subject can include the entity’s trade license number, date established, line of business, licensing authority, and ownership structure.
       •Involved suspected transactions (usually identified in chronological order by date and amount) [To be included only for an STR and supplementary reports involving transactions].
       •The review period for the suspicious activity or transactions.
       •The source of funds, destination of funds, and total of suspected amounts. This can include the transactor and beneficiary information, providing as much detail as possible, including the name and location of any involved domestic and/or international financial institution(s); names, addresses, account numbers, and any other available identifiers of originator and beneficiary transactor(s); and/or third parties or business entities on whose behalf the conductor was acting; the date(s) of the transaction(s); and amount(s).
       •Explain in detail the reason for the suspicion, and why the activity or transaction is determined to be illegal or suspicious.
       •Description of the method of operation (i.e., modus operandi).
       
       Additional Guidance:
       
       •A breakdown of larger volumes of financial activity into categories of credits and debits, and by date and amount. [To be included only for an STR and supplementary reports involving transactions].
       •An explanation of any observed relationships among the transactors (e.g., shared accounts, addresses, employment, known or suspected business relationships and/or frequency of transactions occurring amongst them; appearing together at the LFI and/or counter). [To be included only for an STR and supplementary reports involving transactions].
       •Specific details on cash transactions that identify the branch(es) where the transaction(s) occurred, the type of transaction(s), and how the transaction(s) occurred (e.g., night deposit, on-line banking, ATM, etc.). [To be included only for an STR and supplementary reports involving transactions].
       •Any factual observations or incriminating statements made by the suspect.
       
       •Conclusion
       
       The final paragraph will be covered under “Action Taken by Reporting Entity” field. The final paragraph of the narrative can summarize the report and might also include:
       
       •Any planned/initiated mitigating steps, including information about any follow-up actions conducted by the LFI (e.g., intent to close or closure of accounts, ongoing monitoring of activity, etc.).
       
       Additional Guidance:
       
       •Names and telephone numbers of other contacts at the LFI if different from the point of contact indicated in the report.
       •A general description of any additional information related to the LFI that may be made available to law enforcement by the LFI.
       •Names of any law enforcement or department/unit investigating the case who are not already identified in another section of the report.
       

      2 https://www.namlcftc.gov.ae/en/high-risk-countries.php
      3 Idem note

    • 3.3. Best Practices for Drafting an STR or SAR

      In general, a narrative should identify the five core components - who? what? when? where? and why? -of the suspicious activity being reported to the FIU. The method of operation/modus operandi (or how?) is also important and should be included in the report narrative. An LFI should ensure that the following five questions are answered prior to submitting an STR, SAR, or other report in the FIU’s goAML system.

      Who is conducting the suspicious activity or transaction?

       •Describe the subject of the STR, SAR, or other report, otherwise known as the suspect(s), including the conductor, beneficiary, and accountholders involved in the transaction or activity.
       •Provide identifying information on the parties involved in the transaction, such as the suspect’s occupation and position or title within the business.
       •List beneficial owners, directors, officers, and those with signing authority, if possible. If the transaction or activity involves an entity, include information on the ownership, control, and structure of the business.
       •Provide details about each individual or entity's role in each of the financial transactions described. It is important to understand who is sending and receiving the funds. [To be included only for an STR and supplementary reports involving transactions].
       •If more than one individual or entity is involved in the suspicious activity, explain the relationships among the individuals or entities (if known).
       

      Even though information may not always be available, information should be included to the extent possible. For instance, addresses for suspects are important; filing LFIs should note not only the suspect’s primary street addresses, but also, other known addresses. Any identification numbers associated with the suspect(s) such as passport and driver’s license numbers are also important to document.

      What instruments or mechanisms are being used to facilitate the suspicious activity or transaction(s)?

       •Review the instruments or mechanisms used in the suspicious activity (e.g., wire transfers, foreign currency, Wages Protection System (WPS), letters of credit and other trade instruments, correspondent accounts, money orders, credit/debit cards, etc.).
       •Understand the number of different methods employed for initiating the negotiation of funds, such as the Internet, phone access, mail, night deposit box, remote dial-up, couriers, or others.
       •Describe the source of the funds (as originator) or use of the funds (as beneficiary). In documenting the movement of funds, identify all account numbers at the LFI affected by the suspicious activity or transaction and when possible, provide any account numbers held at other LFIs and the names/locations of the other LFIs involved in the reported activity.
       

      When did the suspicious activity or transaction take place?

       •If the activity takes place over a period of time, provide the date when the suspicious activity or transaction was first observed and describe the duration of the activity.
       •To better understand the history and nature of the activity, and the flow of funds, LFIs should provide information on each individual transaction in a chronological order (e.g., individual dates and transaction amounts, rather than only the aggregated amount). [To be included only for an STR and supplementary reports involving transactions].
       •Provide information on when the transaction was completed or attempted. If the transaction was not completed, the LFI should indicate this in the narrative. [To be included only for an STR and supplementary reports involving transactions].
       

      Where did the suspicious activity or transaction take place?

       •Explain if multiple offices of a single LFI were involved in the suspicious activity or transaction being reported. Provide the addresses of those locations.
       •Specify if the suspected activity or transaction(s) involves a foreign jurisdiction. In this case, list the foreign jurisdiction, LFI, address, and any account numbers involved in, or affiliated with the suspected activity or transaction(s).
       •This information should include any location involved in the full transaction chain, including ultimate originators and beneficiaries to the extent this can be ascertained. [To be included only for an STR and supplementary reports involving transactions].
       

      Why does the LFI think the activity or transaction is suspicious?

       •Describe the industry or business and why the activity or transaction is unusual for the customer. Consider the types of products and services involved in the activity and the expected activities of similar customers.
       •Assess why the activity created a red flag for the LFI or triggered an alert within the system.
       

      These answers will vary based on the LFI type (for example, a depository institution versus an insurance company) and an LFI should also consider such factors as:

       •The types of products and services the LFI offers;
       •The types of accounts the customer has with the LFI;
       •The normally expected business activity of the customer (if they are a customer of the LFI), and why this is not normal or expected activity;
       •The purpose of the payment or transaction, to the extent known, reported, alleged, or questioned; and
       •If the activity resulted from an automated alert, the scenario or rule that generated the alert.
       

      How did the suspicious activity or transaction occur?

       •Describe how the transaction or pattern of transactions was committed (i.e., the “modus operandi” or the method of operation). [To be included only for an STR and supplementary reports involving transactions].
       •For example, if there appear to be multiple cheques deposited matched with outgoing wire transfers from the accounts, the narrative should include information about both the cheques and outbound transfers (including dates, destinations, amounts, accounts, frequency, and beneficiaries of the funds transfers).
       

      • 3.3.1. Defensive STR or SAR Filings4

        Defensive filing is the practice of filing STRs or SARs on transactions or activity(ies) that LFIs do not deem truly suspicious in order to reduce the risk of regulatory penalties for non-filing of STRs or SARs.5 Although there may be some aspect of the transaction or activity creating potential suspicion, defensive filings do not report on activity that the LFI truly considers suspicious. As such, defensive filings are generally discouraged given that such filings diminish the value of STRs and SARs, including by leading to an increase in non-valuable filings. An STR, SAR, and other report types should be of the best possible quality, including in that it should have a clearly written narrative with sufficient detail that comprehensively articulates the factors involving the reported suspicious transaction or activity. As a result, the CBUAE considers defensive STR or SARs as indicative of an inefficient transaction monitoring system and an LFI’s weak system of internal controls. An LFI may be asked to correct such deficiencies as part of broader supervisory measures provided by applicable law, including administrative sanctions, temporary limitation to business activities, etc. If, for any reason, an LFI needs additional data to assess whether unusual activity is truly suspicious, the LFI should review other mechanisms—such as expanding the time period for reviewing alerted transactions (e.g., from 30 days to 90 days) or reviewing threshold-based reports—to make the determination that an STR or SAR is required.

        4 The UAE FIU has noted instances where SAR or STRs are reported due to the LFI not receiving supporting documents that would justify the transaction or activity. However, upon the FIU raising a request to the same LFI in the form of an AIF, supporting documents were subsequently provided for the same subjects and report. This documentation in some instances removed the suspicion of the transaction and in others, helped explain the transaction or action. Submitting reports to the FIU without first conducting a thorough investigation and looking at all available evidence creates a situation where non-suspicious transactions may be reported to the FIU. LFIs are reminded that internal investigations into the suspicious transaction or activity should be conducted to the fullest extent possible prior to raising an STR or SAR and that related documentation, when available or easily retrievable, should be included with the STR or SAR. 
        5 Egmont Group, Enterprise-wide STR Sharing: Issues and Approaches, Pg. 17

    • 3.4. How to Submit an STR and Other Report Types

      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.

       

    • 3.5. Amendments to Submitted Reports

      Once a report is submitted and accepted in the system, neither the Compliance Officer, MLRO, nor FIU employees can apply any changes and amendments to the report for missing or incorrect information. However, LFIs may be requested to file a corresponding AIF, AIFT, RFI, or RFIT, and mention in the “Description of the Report” field the reason of filing. LFIs should ensure that the filer uses the correct web reference number of the initial report. In order to avoid such incident(s) and in order to safeguard the system data integrity, LFIs should adopt a maker and checker process/concept to verify the quality and accuracy of uploaded information.