goAML Registration in the UAE: What VASPs and DNFBPs Need to Know

Who needs to register

Financial institutions, virtual asset service providers and designated non-financial businesses and professions (DNFBPs) with UAE AML/CFT obligations must register on goAML. DNFBPs include real estate agents, dealers in precious metals and stones, corporate service providers and accountants, among others.

What goAML is used for

• Suspicious transaction reports (STRs) and suspicious activity reports (SARs)
• Sanctions reports: Confirmed Name Match Reports (CNMR) and Partial Name Match Reports (PNMR)
• Sector reports, such as the Dealers in Precious Metals and Stones Report (DPMSR) and the Real Estate Activity Report (REAR)
• Receiving communications and requests from the FIU

Getting reporting right

Good reports are timely, complete and clear about why the activity is suspicious. Firms should have an internal escalation route to the MLRO, a documented decision for every escalation, and a strict policy against tipping off the customer.

Sanctions and goAML

Targeted financial sanctions are supervised by the Executive Office for Control and Non-Proliferation (EOCN). Firms must register for the EOCN Notification Alert System, screen customers and transactions, and freeze funds without delay (within 24 hours) on a match. The freeze is then reported through goAML as a Confirmed Name Match Report or Partial Name Match Report within five business days.