Top goAML Mistakes That Trigger FIU Follow-Ups

Avoid These Common Errors That Put Your Business on the FIU’s Radar

Introduction

Every DNFBP in the UAE, from real estate brokers to gold traders and corporate service providers, knows that goAML reporting is mandatory, but not everyone realizes that certain mistakes can quietly trigger FIU attention, even if the report was submitted on time.

The FIU (Financial Intelligence Unit) reviews reports not only for content but also for consistency, quality, patterns, and red flags in how you submit. Some businesses repeatedly make the same errors, resulting in:

  • follow-up requests,
  • clarification questions,
  • delayed approvals,
  • and in some cases, deeper scrutiny.

This blog highlights the top goAML mistakes that can draw unnecessary attention, and how to avoid them.

1. Submitting an STR/SAR With Vague or Generic Descriptions

FIU analysts read the narrative section carefully.

Common mistakes include:

  • “Suspicious behavior observed” (too vague)
  • “Customer acted strange” (unclear)
  • “High-risk customer” (no justification)

Why it triggers follow-up:

The FIU needs facts, time, context, actions taken, and specific reasons for suspicion.

How to avoid it:

Use the 5×5 narrative rule:

  • Who
  • What
  • When
  • Where
  • Why suspicious

2. Misunderstanding REAR Reporting Triggers

Many real estate brokers still misunderstand when a REAR report must be submitted. The rules are simple:

REAR is triggered by the payment method, not the property value

You must submit a REAR only when:

  1. Cash or crypto of 55,000 AED or more (full or partial), or
  2. A third-party makes the payment, or
  3. There is suspicious activity linked to the transaction.

PEP involvement does NOT trigger a REAR

If the customer is a PEP, this alone does not require a REAR.

Instead, it requires an internal PER assessment (Politically Exposed Report).

A REAR is only needed if a separate REAR trigger exists (cash/crypto, third-party payment, or suspicion).

3. Wrong Report Type (STR vs SAR vs REAR)

The FIU receives thousands of misclassified reports.

Examples:

  •  Submitting a REAR when the situation involves suspicious activity or suspicious transactions → should be an STR.
  • Submitting an STR when there is no actual suspicion → should be a SAR (or no report, depending on the case).
  • Submitting a SAR for a weak or non-suspicious case → should not be reported at all.

Why it triggers follow-up:

Analysts will contact you to re-file or justify the type selected.

4. Incomplete or Incorrect Customer Identification Data

Common errors:

  • Missing Emirates ID expiry dates
  • Wrong nationality
  • Incorrect date of birth
  • Company name mismatched with trade license
  • UBOs not listed

Why it triggers follow-up:

The FIU cross-checks identity details with government systems.

If fields don’t match official formats → they ask for clarification.

5. Leaving Mandatory Fields Blank or Filled Incorrectly

Typical mistakes:

  • Putting “N/A” in critical fields
  • Filling long-text fields with one-word answers
  • Using dashes (-) for missing information
  • Uploading blank attachments

Why it triggers follow-up:

goAML automatically flags poor-quality submissions for analyst review.

6. Missing or Wrong Supporting Documents

Examples:

  • Uploading SPA without ID documents
  • Title deed missing for property transactions
  • Attaching a passport copy instead of Emirates ID
  • No evidence of transaction (bank receipt, cash receipt, etc.)

Why it triggers follow-up:

Analysts cannot validate the report without documents.

7. Submitting Contradictory Information Inside the Report

This is one of the biggest hidden triggers.

Examples:

  • Buyer name in Subject section does not match Buyer name in Transaction section
  • Cash amount differs between narrative and transaction fields
  • PEP marked in narrative but “No” in PEP checkbox

Why it triggers follow-up:

goAML’s validation engine highlights inconsistencies → manual analyst review.

8. Submitting Reports Long After the Incident Happened

Late STRs or REARs create FIU suspicion that the business does not have proper monitoring.

Why it triggers follow-up:

Delay can be interpreted as:

  • weak internal controls,
  • lack of awareness, or
  • potential deliberate non-reporting.

Clarification Note:

Under UAE AML law, STRs and SARs must be submitted “without delay” once suspicion is identified. The legislation does not specify a fixed number of days, but regulators expect reporting to happen as soon as the suspicious activity becomes clear, not weeks later.

For comparison, FIU guidance for other report types (like DPMSR) sets a maximum of within two weeks of the transaction, which shows the regulator’s expectation for timely reporting.

In practice, a DNFBP should aim to file STRs/SARs within a few days of identifying suspicion. Longer delays almost always attract FIU follow-up because they suggest ineffective monitoring or slow escalation procedures.

9. Copy–Paste Repetitive Narratives

Some entities reuse the same narrative for every STR.

The FIU sees this immediately.

Why it triggers follow-up:

It suggests:

  • no real investigation was done,
  • poor internal controls,
  • reporting done “just to comply.”

10. Submitting Too Many Weak SARs

SARs should only be submitted when there is genuine suspicion, not uncertainty or low-quality cases.

Why it triggers follow-up:

When a business submits many weak or unjustified SARs, it signals to the FIU that the company may have:

  • poor risk assessment,
  • weak internal judgment,
  • confusion about when to use STR vs SAR.

This pattern often prompts the FIU to reach out, request clarification, offer corrective guidance, or in some cases, review the entity’s reporting practices more closely.

Clarification Note:

Here, “weak SARs” is not about AML red flags.

It refers to SARs that contain little or no real suspicion, meaning the report itself is weak, not the client’s behavior.

These weaken the quality of reporting and increase the workload for the FIU, which is why they attract attention.

How to Avoid FIU Follow-Ups (Practical Checklist)

  • Use structured internal templates
    Especially for STR, SAR, and REAR.
  • Validate identity fields before reporting
    Cross-check Emirates IDs, passports, and trade licenses.
  • Ensure narrative quality
    Always include who, what, when, where, and why.
  • Maintain an internal evidence file
    IDs, receipts, SPA, contracts, emails, and notes.
  • Train your team on STR / SAR / REAR differences
    This alone prevents many reporting errors.
  • Use AML software (like InfoAML)
    To centralize documents, reduce inconsistencies, and maintain a complete audit trail.

How InfoAML Helps Prevent These Mistakes

InfoAML reduces goAML issues by:

  • Centralizing customer and transaction data
  • Ensuring screenshots, IDs, receipts, and notes are stored as evidence
  • Providing clean data for STR/SAR/REAR prep
  • Reducing inconsistencies with structured internal fields

Future versions will include:

  • Pre-submission data validation
  • Error-prevention prompts
  • goAML-ready XML generation

Conclusion

Most FIU follow-ups are preventable.

They are not caused by “suspicious customers”, but by incomplete, inconsistent, or low-quality reports.

By improving your internal process, training your team, and using proper AML tools, you can file accurate, high-quality reports that the FIU can trust, without unnecessary follow-up calls.

👉 Stay goAML-Ready, Every Time

InfoAML helps UAE DNFBPs prepare accurate, clean, FIU-ready reports.

🚀 Request a free AML demo and avoid the mistakes that trigger FIU follow-ups.

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