2 min read
The goAML platform: registration, reporting, and what businesses are actually penalised for
The Ministry of Economy suspended dozens of businesses for three months over failure to register on the platform. This obligation in particular is monitored and enforced.
goAML is a platform developed by the United Nations Office on Drugs and Crime, used by the UAE Financial Intelligence Unit to receive reports. It is not an optional awareness site but the official channel through which the reporting obligation is discharged.
The Ministry of Economy has previously suspended the operations of dozens of designated non-financial businesses for three months over failure to register. The signal is unambiguous: registration is monitored and enforced.
Who must register?
Businesses subject to AML obligations, covering financial institutions and the designated non-financial businesses and professions:
- Real estate brokers and agents
- Dealers in precious metals and stones
- Auditors and accountants
- Company and trust service providers
- Lawyers, notaries and independent legal professionals when carrying out defined activities
STR or SAR?
| Type | When it is used |
|---|---|
| Suspicious Transaction Report (STR) | Where the suspicion concerns a specific transaction carried out or attempted |
| Suspicious Activity Report (SAR) | Where the suspicion concerns behaviour or a pattern rather than one transaction |
Confusing the two is common. What matters practically is that both are filed through the same platform, and that delay is not cured by filing something more detailed later.
When is a report filed?
When there are reasonable grounds for suspicion. Note the phrase: **reasonable grounds for suspicion** — not certainty, not proof. A business is not an investigating authority; its duty is to report when the grounds arise, not to establish that a crime occurred.
The tipping-off prohibition
You may not tell the customer or any party that a report has been filed or is being considered. The 2025 law tightened this: the tipping-off offence now covers both intentional and grossly negligent acts, with aggravated penalties where it results in the loss or destruction of criminal proceeds.
Common registration mistakes
- A registration left incomplete pending a document, then forgotten
- Compliance officer details never updated after they left, so alerts reach nobody
- Registering without anyone being trained to actually use the platform
- Failing to update entity data after a material change in activity or ownership
The obligation begins after registration
Registration is an administrative step completed once. The real obligation is continuous: monitoring transactions, detecting patterns, filing when grounds arise, and keeping what evidences that you did.
A registered business that has never filed a report is not necessarily in breach — but it needs to show it has an effective detection mechanism, rather than an absence of reports caused by an absence of monitoring.
