10 Jul 2020
goAML is an anti-money laundering (“AML”) reporting platform developed by the Information Technology Service of the United Nations Office on Drugs and Crime (“UNODC”) in partnership with the UNODC Global Programme Against Money Laundering, Proceeds of Crime and the Financing of Terrorism.
Essentially, the goAML software has been designed as a modular system which is capable of being implemented as part of any Financial Intelligence Unit (“FIU”), irrespective of its size.
FIUs have an active role in the prevention of anti-money laundering and counter-terrorist financing (“AML/CFT”) activities, primarily because they receive reports of suspicious transactions or suspicious activity from Subject Persons (or Obliged Entities). The Maltese FIU has fully introduced the goAML platform and replaced the old STR Submission System already. Consequently, all Subject Persons in Malta are required to be registered on the goAML platform, whereby, going forward, should they want to report any suspicious activity or transaction, they will do so via the goAML platform.
Subject Persons must first register, then login to the Maltese FIAU’s goAML portal, then choose whether to provide an XML upload or a Web Report, and finally enter the relevant information and documentation as required.
Subject Persons are also required to choose the type of report which they are raising, since the report will be handled depending on the nature of the report raised. Subject Persons are to choose between the following: (i) Suspicious Transaction Report (STR); (ii) Suspicious Activity Report (SAR); (iii) Terrorism Financing Report (TFR); (iv) Politically Exposed Person Report (PEPR).
Following an update issued by the FIAU on the 17th of June 2020, the FIAU has granted an extension with respect to the deadline imposed on all reporting entities opting for XML integration with goAML.
Thus, all reporting entities wishing to integrate XML with goAML have until 22nd August 2020 to do so, and this in view of various technical difficulties which reporting entities were having.
This deadline does not relate to the FIAU’s goAML web forms for the purposes of submitting STRs, and goAML should still be used for submitting STRs, SARs, TFRs and PEPRs, also considering that the old system of online submission is not available, and such reports cannot be delayed when there is a suspicion of money-laundering or terrorist financing.