Annex 4. Overarching Rules and Principles for the goAML System

Effective from 7/6/2021

The FIU published the goAML XML Submission Guide (please see Section 3.4) with additional detail on the rules that an LFI should consider when submitting an STR, SAR, or other report type in the goAML system:

	•	All LFIs transactions should be reported as bi-party transactions on the goAML system.
	•	Reporting entities should submit only suspicious transactions in a report. Any additional transactions can be submitted via an AIFT (upon request only).
	•	For AIFT submissions where the number of transactions exceed 10,000, reporting entities are advised to split them into more than one AIFT; however, the AIFT should use the same “Internal Reference Number”.
	•	A deposit is composed of a bi-party transaction occurring from a person who may be a conductor to an account.
	•	A withdrawal is composed of a bi-party transaction occurring from an account to a person.
	•	A remittance is composed of a bi-party transaction occurring from one person/account/entity to another.
	•	A wire transfer is composed of a bi-party transaction occurring from an account to another account.
	•	In case a LFI is acting as a correspondent bank within a reported transaction, then the transaction is occurring from one account to another, in which both accounts should be classified as ‘Not My Client’ by the LFI/Compliance Officer/MLRO.
	•	In the case of Exchange Houses, where a currency exchange transaction is being reported, it should be reported as a bi-party transaction, where the “from” and “to” parties are the same Person.
	•	The conductor field is mandatory when the transaction is conducted from an entity.
	•	If the date of birth for a subject (person) is unknown, then the user may enter the 1st of January 1900 in the ‘Birth Date’ field.
	•	In case the expiration date of a registered ID is unknown, then the user may enter the 31st of December 2100 in the ‘Expiry Date’ field.
	•	When reporting a transaction that involves an account, it is imperative that the LFI also provide details for the person or entity associated with the said account.