Introduction to the GoAML System in the UAE
In recent years, the government of the United Arab Emirates (UAE) has significantly strengthened measures against money laundering (AML) and terrorism financing (CFT). In a notable shift in approach to monitoring financial transactions and high-risk activities, the state's efforts to be removed from the FATF's grey list, which was successfully achieved in February 2024, played a crucial role. As one of the leading financial centers globally, the UAE recognizes the importance of establishing a robust and efficient system to prevent financial crimes. This led to the implementation of the GoAML system, developed under the auspices of the United Nations.
GoAML is an advanced integrated platform designed to collect, analyze, and disseminate information about suspicious financial transactions and activities. The system provides financial institutions and other obligated entities with tools for effective data management of suspicious operations, a key element in the country's AML/CFT strategy.
Registration in the GoAML system is mandatory for a wide range of organizations, including financial institutions and designated non-financial businesses and professions (DNFBPs), such as real estate, legal and accounting services, and traders of precious metals and stones. This ensures a comprehensive approach to tracking and preventing suspicious transactions at the national level.
Stages of Registration on the GoAML Portal
Registration on the GoAML portal in the UAE is a crucial step for all financial and certain non-financial organizations to comply with AML/CFT legislative requirements. The registration process consists of two stages and requires careful data entry and verification.
Stage 1: Registration in the SACM system
The first step involves registering in the SACM (Secure Access Control Management) system, which provides a unique username and secret key. These credentials are necessary for setting up Google Authenticator, which provides two-factor authentication for additional security access to the GoAML system.
Stage 2: Registration on the GoAML portal
After obtaining the SACM credentials, the next step is to register on the GoAML portal itself. Here, it is necessary to provide detailed information about the company, including its legal name, address, license data, and personal information of the Compliance Officer. It is crucial to ensure that all information is accurate and current, as it will be used for identification and verification within the system.
Upon completing these two stages, the organization gains access to the functions of the GoAML portal, enabling effective management of reports on suspicious transactions and activities and compliance with AML/CFT requirements.
Categories of Organizations Required to Register in GoAML
According to Federal Decree-Law No. (20) of 2018 and Article 20(2) of the Cabinet Resolution No. (10) of 2019, the UAE defines a range of organizations that must be registered in the GoAML system. This requirement extends not only to financial institutions but also to various non-financial companies and professional services (DNFBPs) that could be used for money laundering or terrorism financing.
Organizations required to register include:
Real estate firms: Given the significant amounts of money handled in real estate transactions, these firms can become targets for money laundering.
Companies providing audit or accounting services: Such services can be used to create complex financial structures that obscure the origins of funds.
Trust companies: Managing assets through trusts can facilitate the concealment of true beneficiaries.
Consulting firms and corporate service providers: Consulting services may include financial planning advice that can be used for money laundering. Newly established and existing companies can be infused with criminal money.
Legal firms: Except for lawyers and notaries, legal firms may be involved in creating legal structures that facilitate money laundering.
Companies trading in precious metals or stones: Trading in valuable items can be used to transfer and conceal illegal proceeds.
The Importance of Registration: Registering in the GoAML system allows organizations not only to comply with legislative requirements but also contributes to national and international efforts to combat financial crimes. It also helps strengthen the reputation of companies as reliable and responsible market participants.
Penalties for Non-compliance with GoAML Requirements
Non-compliance with GoAML system requirements in the UAE can lead to serious financial and legal consequences for organizations. It is important to understand potential fines to avoid violations and maintain honest business operations.
Examples of penalties for violations:
Non-compliance with risk identification procedures: Fines can reach up to 100,000 AED for failing to perform necessary actions and procedures for risk identification related to the organization's activities.
Violation of risk assessment procedures: A similar fine of 100,000 AED may be imposed for failing to identify and assess risks when developing new services or professional practices.
Ignoring risk mitigation measures: Non-compliance with actions and procedures for mitigating risks identified based on the National Risk Assessment may lead to a fine of 50,000 AED.
Lack of internal policies and control mechanisms: Non-compliance with internal policies and procedures to prevent suspicious business relationships may cost an organization 50,000 AED.
Inadequate management of high risks: For failing to take necessary enhanced measures to manage high risks, a fine may amount to 200,000 AED.
Insufficient management of low risks: Not taking simplified measures to manage low risks may lead to a fine of 50,000 AED.
Non-compliance with customer verification procedures (KYC): Not conducting necessary customer verification measures before establishing business relationships may incur a fine of 100,000 AED.
These fines are part of the UAE government's efforts to ensure compliance with AML/CFT legislation and maintain the country's reputation as a safe and transparent financial center. Organizations must strictly follow established procedures and regularly update their AML/CFT policies to avoid these fines.
Make Fortune Specialized Services for AML/CFT Compliance
Make Fortune offers a wide range of consulting services in anti-money laundering (AML) and counter-terrorism financing (CFT), helping organizations comply with UAE legislative requirements and international standards. Our services include:
Assistance in developing AML/CFT policies: We help companies develop and implement effective AML/CFT policies and procedures that match their unique business models and risks.
Information provision to staff: Make Fortune enhances staff awareness and competencies in AML/CFT
Audit and risk assessment: Our specialists conduct audits and AML/CFT risk assessments to identify potential vulnerabilities and suggest measures to address them.
Support in registering in the GoAML system: We provide assistance in the GoAML registration process, including preparing necessary documentation and filling out applications.
Consultations and support: Our team of experts provides consultations on AML/CFT issues and support in case of checks or audits by regulators.
Ongoing accompaniment and updates: Make Fortune offers ongoing accompaniment and updates of AML/CFT policies and procedures in line with changes in legislation and best industry practices.
Collaborating with Make Fortune not only helps companies avoid fines and penalties but also strengthens their reputation as responsible market participants. If you have questions about our services or would like to learn more about how we can assist your organization, please contact us.
