Questions & Answers – goAML Web 5.0 presentation 25/08/2022

Please find below the list of questions during the presentation of the goAML Web 5.0:

Will the presentation be made available?

The presentation is already available on our FAQ: goAML 5.0 or Documents utiles

Do we get a certificate for following this training­?

Unfortunately, we cannot send any certificates.

Does the update include pre-filling of business address for the delegate / AMLO submitting the report?

The element Location underneath the Reporting Person element: Location is not meant for your business address – it is meant for the location of the suspicion – Location – and it is not a mandatory field. Furthermore, this element will be hidden in the 2nd phase.

Some fields will become mandatory in the Account element: what do we do if we don’t have accounts?

Those fields become mandatory only if you add an account element in your report. If you do not have accounts, simply don’t add an account to the report and only your client – a person and/or entity. By not adding an account, the fields pertaining to the account will not be present, hence not mandatory.

For SARe and STRe, will <reporting_person> remain mandatory?

The element <reporting_person> is already not mandatory.

It was mentioned that for SARe/STRe max size will remain 20MB. In one of the following slides it was mentioned characters limit will increase from 4000 to 8000 characters. Will this character increase apply also to SARe/STRe?

The characters limit will increase from 4000 to 8000 characters; this also applies to SARe/STRe.

Will the number of attachments that can be attached to a report increase from the current maximum of 20 files?

Unfortunately, we can’t currently raise the limit of number of attachments per report.

I am the third-party RC on a number of funds (stand-alone entities, not having the same IFM) and always had to obtain 1 LuxTrust Professional token for each fund/entity. It is quite burdensome having to carry many tokens around. Is it really still necessary to have 1 token in the name of the entity or is this something that will change in the future, i.e. that a third-party RC can just use a LuxTrust token in the name of the third-party RC’s employer?

goAML 5.0 includes no change to this behavior. For your information, please check whether you can use the functionality of delegations: Delegation & Q&A for investment sector: Documents utilesQ&A investment funds

What will happen to current draft reports (web form) that will be submitted after 2nd September ? Will they be automatically updated ? Or should we draft new web form with 5.0 version ?

There should be no problem, but we have not tested the system’s response to all possible scenarios where information present in the draft would be hidden after the upgrade. To be on the safe side, we recommend to finalise and submit your reports as far as possible before 2nd September.

How can we change the main entity registered on goAML under which other entities under management are registered?

In order to change the main entity, the delegation needs to be changed – in goAML – active organisations – Delegations

Indicating non-transacting accounts together with transacting accounts: Would this apply to xml loads as well, so there would be no need for separate load of a SAR/RIRA xml file?

Yes, absolutely.