Comprehensive Guide to GoAML Compliance in UAE for Businesses
What is AML?
AML refers to the laws, regulations, and procedures that institutions and businesses implement to detect, prevent, and report money laundering activities. Federal Law No. 20 of 2018 provided the foundation for the UAE’s anti-money laundering efforts. It also outlines obligations for financial institutions and businesses to detect and report suspicious activities. Further, Cabinet Resolution No. 10 of 2019 and Central Bank Circulars strengthen AML measures.
What is GoAML?
GoAML stands is a specific platform developed by the UAE’s Financial Intelligence Unit (FIU) under the Central Bank of the UAE to comply with the AML laws.
Why is it important?
- GoAML helps FIU to combat money laundering and terrorist activities.
- GoAML helps FIU to investigate the cases of money laundering, terrorist laundering, and other serious financing.
To whom is GoAML applicable?
Business entities engaged in the below activities are considered Designated Non-Financial Businesses and Professions (DNFB) to whom the provisions of GoAML are applicable.
- Dealers of Precious Metals and Gemstones
- Brokers and Real-Estate Agents
- Corporate Service Providers
- Independent Accountants and Auditors
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What steps need to be taken to comply with AML?
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Registration:
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- Keep the necessary documents such as trade license, memorandum of association, passport and emirates ID of owners and compliance officer, proof of authorized signatory, ready for smooth registration process.
- The business entities who are considered as DNFB are required to register on the website https://services.cbuae.gov.ae/
- Create your account by selecting appropriate entity type and accurate details.
- Appoint a compliance officer responsible for monitoring the AML compliance and reporting.
- Upload supporting documents and wait for the FIU to approve your registration.
- Up on receiving the approval mail, you can login using the credentials shared in such mail.
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Internal policies and compliance:
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Preparation of Policy & Procedures:
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The DNFB will have to prepare and maintain internal policies, procedures, and controls to prevent crimes, corresponding to the nature and size of their business and the risk of crimes. Such policies must be updated regularly and applied to all branches and subsidiaries in which it holds a majority interest.
A few of the contents of the internal policy can be as below-
| Sl. No | Table of Contents |
| 1 | Definitions |
| 2 | Background And Scope |
| 3 | Applicability And Effective Date |
| 4 | Identification And Assessment Of ML/FT Risk |
| a | Customer Due Diligence (CDD) |
| b | Enhanced Due Diligence (EDD) |
| c | Simplified Due Diligence (SDD) |
| 5 | Suspicious Transaction Reporting (STR) |
| a | Fund Freezing Report |
| b | Partial Name Match Report |
| c | Screening Of Politically Exposed Persons |
| d | Target Financial Sanctions with The Approved Supervisory Body |
| e | Red Flag Indicators |
| f | Tipping Off |
| 6 | Entity Governance |
| 7 | Record Keeping |
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AML Training Program:
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Conduct training programs for employees on how to use the platform to comply with AML and Counter Terrorism Financing (CTF). The training can focus on key aspects like registration, reporting suspicious activities etc. By equipping the employees with this knowledge, entities can comply with the provisions and reduce risks.
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Customer Risk Assessment Form and individual client risk profile:
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The customer due diligence has to be conducted by identifying or verifying the information of a customer or beneficial owner, whether natural or legal person, the nature of business activity, the purpose of the business, the relationship, and the ownership structure and control over it.
Prepare a KYC form including all important and relevant information of the clients while onboarding the client to comply with this requirement.
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Screening tools:
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The business entities must perform screen tests for their customers. It has to be evaluated whether the client is high or low risk.
Pro-tip: Perform the screening of your clients while onboarding them to avoid missing any screenings.
Get insights into screening tools with accounting software in Dubai.
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Documenting the AML Training register:
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Document the register on AML training and employee attendance registers for the financial years 2023 and 2024. This acts as proof that the meetings were conducted in the past.
Maintain comprehensive records of customer identification, transactions, and reports filed through GoAML. Ensure these records are stored securely and are easily accessible for future audits or inquiries up to 5 years.
Understand VAT filing mistakes to avoid penalties under AML.
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External
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Compliance:
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- Submit annual risk assessment for each financial year in the portal of Ministry of Economy. The link is given here- https://amlquestionnaire.moec.gov.ae/#/login
- Collect all the necessary data to maintain financial transparency and to prevent possible legal violations.
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Be prepared for inspections:
- Ensure the compliance officer is registered.
- The regulatory authorities such as Ministry of Economy and Free Zone authorities will conduct regular inspections. Therefore, keep all relevant documents handy.
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Learn how corporate tax laws in the UAE affect AML compliance.
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