STR and goAML Reporting Services:
A Suspicious Transaction Report (STR) is a formal report submitted by a regulated entity when it has reasonable grounds to suspect that a transaction, attempted transaction, or business relationship may involve:
- Proceeds of crime
- Money laundering
- Terrorist financing
- Sanctions breaches
- Or other unlawful activity
goAML reporting refers to the electronic submission of that suspicious Transaction Report through the official goAML platform operated by the UAE Financial Intelligence Unit. All reporting entities across the Mainland and Free Zones must be registered on this system and operationally ready to submit reports when required.
Across sectors such as VASPs, asset managers, securities firms, insurance providers, payments and fintech companies, real estate brokers, accountants, lawyers, TCSPs, and DPMS, the obligation is uniform. If suspicion arises, silence is not an option.
Would Your Next STR Withstand Inspection?
We Examine Your Escalation Timelines, Narrative Quality, and Documentation Trail before a Supervisor Does
A Legal Duty, Not a Commercial Choice
STR and goAML Reporting in the UAE is a statutory obligation under the UAE AML Law, supported by Federal Decree Law No. 10 of 2025 and Cabinet Resolution No. 134 of 2025.
If there are reasonable grounds for suspicion, reporting to the Financial Intelligence Unit through goAML is mandatory. Supervisory expectations then depend on your sector.
Financial institutions respond to the CB UAE AML CFT Rulebook.
DNFBPs such as real estate brokers, accountants, lawyers, TCSPs and DPMS follow the MOECT Guidelines and MOJ Guidelines.
The UAE regulatory framework is aligned with international standards, including the FATF Virtual Asset Guidance and the IOSCO Crypto Asset Principles. Supervisory authorities increasingly assess the substance and analytical quality of STR narratives, rather than merely confirming that a report has been submitted.
The statutory position is unequivocal.
Where reasonable grounds for suspicion exist, reporting is mandatory.
Unjustified delay may constitute a breach.
Inadequate documentation may expose weaknesses in governance and internal controls.
STR and goAML Reporting must therefore be treated as a core compliance function. It serves as a direct indicator of an institution’s regulatory discipline, risk culture, and operational integrity.
The Cost of Hesitation
STR and goAML Reporting failures are typically the result of weak execution rather than the absence of policy. Based on supervisory trends and internal compliance reviews, the following issues frequently arise:
STR and goAML Reporting failures are typically the result of weak execution rather than the absence of policy. Based on supervisory trends and internal compliance reviews, the following issues frequently arise:
The STR is eventually filed, but the reporting timeline is difficult to justify when examined against the date the suspicion first arose.
Red flags are listed as observations, rather than analysed as indicators of potential money laundering or terrorist financing.
Internal escalation to the MLRO is delayed, undocumented, or inconsistently applied.
Commercial considerations influence the timing or substance of the STR filing decision
Address the Gaps Before They Are Examined
We Conduct Focused Reviews of STR and goAML Reporting Processes to Ensure a Legal Defensibility and Governance Clarity
Our Reporting Methodology
The duty to report suspicion is defined by law, not by convenience. STR and goAML Reporting requires a controlled pathway from identification to submission, supported by documented reasoning and timely escalation. Without structure, compliance becomes uncertain at precisely the wrong moment.
Identification of Suspicious Activity
The process begins with the clear identification of potentially suspicious activity. This requires defined detection parameters across transaction monitoring systems, customer due diligence reviews, sanctions screening, and periodic account assessments.
We assess whether red flags are properly calibrated and whether staff understand what constitutes reasonable grounds for suspicion under the UAE AML Law. Suspicion must be recognised consistently and without ambiguity. If detection is uncertain, reporting will inevitably be delayed.
Internal Escalation and Independent Review
Once suspicion is identified, it must be escalated promptly through a clearly defined internal reporting channel.
We design and review escalation frameworks to ensure that alerts reach the MLRO without delay or informal filtering. Escalation thresholds are documented. Responsibilities are assigned. Decision-making authority is clearly established.
The independence of the MLRO is preserved throughout this stage. The reporting decision must be grounded in regulatory obligation, not influenced by operational or commercial considerations.
Compiling and Documenting Findings
Before submission, the institution must assemble a structured and defensible case file.
We ensure that each case file contains a clear timeline of events, a detailed analysis of the activity in question, relevant client information, supporting documentation, and a reasoned explanation of why the activity meets the threshold of suspicion.
Evidence is not merely attached. It is analysed and referenced within the narrative. The documentation trail must demonstrate how the suspicion was identified, reviewed, and confirmed for reporting.
This stage determines whether the final STR reflects governance discipline or procedural uncertainty.
Preparation and Submission through goAML
The final stage involves drafting and submitting the Suspicious Transaction Report through the goAML platform in a timely manner.
We ensure that the narrative is coherent, fact-based, and aligned with the documented case file. The report must clearly articulate reasonable grounds for suspicion and avoid vague or defensive language.
Following submission, we establish internal record retention protocols and, where appropriate, post-report review procedures to assess whether any control enhancements are required.
Submission is not the conclusion of the process. It is a regulatory declaration that must withstand supervisory review.
The Value of Reporting Properly
There is a visible difference between a firm that files STRs because it must and a firm that files them because it knows how. When your STR and goAML Reporting framework is structured properly, you gain leverage, not just compliance.
When a commercially significant client triggers suspicion, the pressure inside the organisation becomes immediate and subtle. A properly structured STR and goAML Reporting framework ensures that the decision to file is guided by statute, not by revenue anxiety or reputational discomfort. That line, once blurred, is difficult to redraw.
Supervisors do not view weak reporting in isolation. A delayed filing or a poorly reasoned narrative often prompts broader questions about governance oversight and risk culture. One fragile STR can widen the lens of scrutiny far beyond a single case.
During inspection, sample testing is rarely about the transaction alone. It is about how the institution behaved when suspicion crystallised. The difference between opening a coherent, timestamped case file and reconstructing events from memory is not cosmetic. It shapes regulatory confidence immediately.
Board accountability now sits closer to operational reality than many assume. Under UAE supervisory expectations, senior management must demonstrate that AML controls function in practice. A disciplined reporting framework provides tangible proof that obligations are met when tested.
Reputation with regulators accumulates quietly. High-quality STR narratives, filed promptly and supported by clear analysis, signal that the institution understands the threshold of suspicion and applies it consistently. Over time, that consistency becomes credibility.
When Reporting Is Done Properly, It Speaks for Itself
Let Us Ensure Your STR and goAML Reporting Framework Reflects the Governance You Intend to Demonstraten.