All you need to know about the GoAML system
The Ministry of Economy (MOE), UAE has prepared comprehensive plans for implementation and compliance with the requirements of Federal Decree Law no 20 of 2018 concerning AML and CFT. In this regard, MOE is vested with the duty of supervising and regulating Designated Non-Financial Businesses and Professions (DNFBP) operating in UAE for AML, CFT and Financing of Illegal Organizations Crimes.
Who are Designated Non-Financial Businesses and Professions (DNFBP)?
Article 3 of the Cabinet Decision 10 of 2019 has defined the following sectors as DNFBP:
- Real Estate Brokers and Agents: Purchase and sale of real estate for their customers
- Dealers in precious metals and stones: Single or multiple related cash transactions exceeding AED 55k
- Lawyers, Notaries, independent legal professionals, independent accountants: Preparing, conducting and executing financial transactions for their customers related to:
- Purchase and sale of Real Estate
- Management of customer funds
- Management of bank, savings or securities account
- Organising funds for establishment, operation or management of cos
- Creation, operation or managing legal persons/arrangements
- Selling/buying Commercial Entities
- Providers of Corporate Services and Trusts: Performing/executing transactions for their customers related to:
- Agent in creation/establishment of legal persons
- Providing Director/Secretary/Partner in a legal person
- Providing registered office/address of a legal person
- Providing Trustee functions for a Trust or similar Legal arrangement
- Providing nominal shareholder setup
- Other professions and activities as decided by Ministry of Economy, UAE
Obligations of DNFBP
- To identify, assess, understand risks related to AML /CFT
- To define the scope of and take necessary due diligence measures
- To appoint an AML/CFT compliance officer, approved by the relevant Supervisory Authority
- To put in place adequate management and information systems, internal controls, policies, procedures to mitigate risks and monitor implementation
- To put in place indicators to identify suspicious transactions
- To report suspicious activity and cooperate with Competent Authorities
- To promptly apply directives of Competent Authorities
- To maintain adequate records
Why register on goAML
Registration in the goAML system is a prerequisite for submitting suspicious transaction reports (STRs). – goAML is an internationally approved electronic system to collect and analyze financial and non-financial information to confront money laundering and combat the financing of terrorism.
Deadline and Penalties
The registration final date is 31st March 2021. In case registration is not done, there are penalties including cancellation of license. Also the administrative penalties relating to non-compliance by DNFBP ranges from AED 50,000 up to AED 5 million.
How can MCA Help?
MCA can facilitate the registration of your entity on the goAML and other related system as required by MOE. Also MCA can help in designing and maintaining the compliance system expected from the entity to fulfil the DNFBP related obligations.
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