High-Risk Country Reporting in the UAE | AML UAE

Introduction

This tutorial provides a comprehensive guide on high-risk country reporting requirements in the UAE, as outlined by the Anti-Money Laundering (AML) regulatory framework. Understanding these requirements is essential for regulated entities to comply with regulations set forth by the Financial Action Task Force (FATF) and to report transactions involving high-risk countries effectively.

Step 1: Identify High-Risk Countries

• Be aware that the FATF has designated certain countries as high-risk, including:
  • Iran
  • North Korea
  • Myanmar
• Transactions involving these countries may require additional scrutiny and reporting.

Step 2: Understand Reporting Requirements

• Regulated entities must file two types of reports:
  • High-Risk Country Report (HRC)
  • High-Risk Country Activity Report (HRCA)
• Both reports serve to capture transactions related to high-risk countries.

Step 3: Determine When to File HRC and HRCA

• High-Risk Country Report (HRC):
  • File when you observe transactions related to high-risk countries during customer interactions.
• High-Risk Country Activity Report (HRCA):
  • File when identifying activities related to high-risk countries during the establishment or course of a customer relationship.

Step 4: Identify Transactions That Require Reporting

• Report any cross-border transactions that involve:
  • Transfer of funds through banking channels
  • Remittances originating from, destined to, or passing through high-risk countries
• Note that the reporting applies regardless of the transaction amount or currency.

Step 5: Filing Process Through goAML Portal

• Transactions must be filed with the Financial Intelligence Unit (FIU) using the goAML Portal.
• Steps to file:
  1. Log in to the goAML Portal.
  2. Select the appropriate report type (HRC or HRCA).
  3. Complete all mandatory fields with necessary transaction details.
• Important: Reports cannot be submitted via physical means, email, or message boards.

Step 6: Handle Missing Information Appropriately

• If you lack complete details for an HRC filing, consider filing an HRCA instead.
• Ensure that all relevant information about the parties involved and the transaction value is adequately captured.

Step 7: Know Exempted Transactions

• Understand that certain transactions are exempt from HRC/HRCA reporting, including:
  • Domestic transactions such as cheques or cash payments by individuals from high-risk countries.
• HRC/HRCA reporting is specifically for international transfers made through banking or remittance channels.

Conclusion

In summary, regulated entities in the UAE must be vigilant in reporting transactions involving high-risk countries as per the AML regulations. By understanding the types of reports required (HRC and HRCA), recognizing the transactions that need to be reported, and following the proper filing procedures, entities can ensure compliance and mitigate risks associated with money laundering. For any questions or clarification, consider reaching out through the comments section for further assistance.