Checklist For Filing STR and SAR on the goAML Portal | AML UAE

Introduction

This tutorial provides a comprehensive checklist for filing Suspicious Transaction Reports (STR) and Suspicious Activity Reports (SAR) using the goAML portal, as outlined in the video by AML UAE. It is crucial for regulated organizations to implement an effective Anti-Money Laundering (AML) and Counter Financing of Terrorism (CFT) program. This guide will help you ensure completeness and accuracy when reporting suspicious transactions to the Financial Intelligence Unit (FIU).

Step 1: Recognize Suspicious Activity

• Frontline employees should be vigilant during customer onboarding and transaction execution for any red flags that indicate potential money laundering or terrorism financing.
• If suspicious activity is observed, report it immediately to the AML Compliance Officer using an internal SAR or STR form.

Step 2: Complete the Internal SAR or STR Form

• The internal form should capture essential details about the suspicious activity, including:
  • Parties Involved: Identify all individuals or entities associated with the suspicious activity.
  • Nature of Suspicion: Describe what makes the activity suspicious.
  • Location: Specify where the incident took place.
  • Date and Time: Note when the suspicious activity occurred.
  • Reason for Suspicion: Clearly explain why the Compliance Officer considers the activity suspicious.

Step 3: Conduct Preliminary Investigation

• Upon receiving the internal report, the Compliance Officer should:
  • Perform a preliminary investigation to gather additional details.
  • Use relevant keywords or descriptions to ensure accurate results.
• Document the investigation process thoroughly.

Step 4: Document Investigation Results

• After the investigation, the Compliance Officer must:
  • Document whether the activity is associated with money laundering or terrorism financing.
  • Record the decision regarding whether to report the activity to the FIU.
  • If no report is filed, provide a clear rationale for the non-reporting decision.

Step 5: Consult Senior Management (If Necessary)

• If deemed appropriate, the Compliance Officer should discuss the findings and investigation results with Senior Management to ensure alignment and transparency.

Step 6: Prepare Required Documentation

• Before filing the STR or SAR, ensure that you have all necessary documents, including:
  • KYC forms capturing the identities of the parties involved.
  • Any relevant transactional documents that support the report.

Step 7: File the STR or SAR on the goAML Portal

• Once the decision to file a report is made, the Compliance Officer should:
  • Access the goAML portal and submit the STR or SAR promptly.
  • Ensure that all information is accurate and complete, as the quality of the report reflects the effectiveness of the AML program.

Conclusion

Filing STRs and SARs accurately is vital for compliance with AML regulations. By following this checklist and adhering to the steps outlined, organizations can enhance their reporting processes and ensure thorough documentation of suspicious activities. For further guidance on AML CFT obligations, stay tuned for additional resources and videos from AML UAE.