As of January 1, 2020, MROS introduced goAML, a system for receiving and processing suspicious activity reports that allows the submission of reports via an online portal.
What does change with goAML and what are the advantages?
- Suspicious activity reports, their attachments and additional information are uploaded and submitted online.
- Documents to be submitted upon request of MROS are no longer faxed or sent by post but instead transferred via the online portal.
- The financial intermediaries have the following three options for entering suspicious activity reports:
- Fully manually: Entry in the online form;
- Fully automated: Reports can be uploaded as an XML file;
- Semi-automated: Entry in the online form, with the involved transactions being integrated into the report by means of an XML file.
How to register for goAML?
In order to be able to enter reports in goAML, prior registration in goAML is required. This registration can be completed at any time via the registration page. An information sheet entitled “Step-by-step Guide to your goAML Registration” is available under the tab “Documents”.
Is it possible to test goAML?
The below tab “Links” provides a test version of goAML.
You will also find a detailed user manual under the tab “Documents”, which will help facilitate the introduction into goAML.
We kindly point out to refrain from entering any real customer data in the test version.
What do I have to consider when entering and transmitting reports via goAML?
Financial intermediaries can enter their reports in goAML as described in the section “What changes with goAML and what are the advantages?” and then transmit them to MROS.
The following important points must generally be observed:
- A maximum of 100 suspicious transactions may be recorded and transmitted per report;
- If, in exceptional cases, the intention is to transmit more than 100 transactions with a report, the reporting financial intermediary must discuss the exact procedure with MROS in advance;
- Securities transactions can be submitted in XML format or in an Excel spreadsheet;
- For the reported (suspicious) transactions, the account and custody account statements of the suspicious period must be submitted in PDF as an attachment;
- If multiple business relationships are reported, at least one (suspicious) BiParty transaction must be entered per reported business relation/account;
- Further accounts and/or securities accounts of the reported business relation(s) as well as additional information concerning natural or legal persons may be recorded by means of so-called MultiParty transaction;
- A statement of assets in PDF format must be submitted as an attachment for all accounts and securities accounts of a reported business relation;
- If, on the other hand, a single account and not the entire business relation is reported, a corresponding account statement showing the current balance is sufficient;
- Additional documents such as opening documents, KYC, any media reports, etc. must also be submitted as attachment;
- All inserts must always be submitted in OCR (character recognition system) format;
- Reports that have been previously written in paper format, subsequently scanned and transmitted as a PDF via Message Board in goAML will not be accepted.
Further information and tips on how to use goAML can be found in the “Fact Sheet Web Reports” and “Adjustment to the practice of reporting via goAML valid from 01.04.2021 (version 2.0)”, both of which are filed under the tab “Documents” tab. A manual with detailed information is also available to users.
How must I proceed from 1.1.2023 in order to submit a termination notification pursuant to art. 9b AMLA?
As of January 1st, 2023, financial intermediaries are allowed, under certain conditions, to terminate a business relationship that has previously been the subject of a suspicious activity report – regardless of whether the report was made on the basis of Art. 9 para. 1 lit. a AMLA or Art. 305ter para. 2 of the Swiss Criminal Code (SCC) – upon expiry of a period of 40 working days following the date of receipt noted on the acknowledgement receipt of the suspicious activity report (new Art. 9b AMLA).
However, financial intermediaries must notify MROS without delay if they terminate a business relationship previously reported to MROS. It should be noted that this provision does not apply to business relationships indicated in reports that have been forwarded to the law enforcement authorities.
The content of such termination notifications of a business relationship is determined in Art. 3 para. 1bis of the Ordinance on the Money laundering office (MROSO).
If it is reported electronically, this notification of the termination of a business relationship must be done by means of a new type of report (CANCL/CANCT), selected under the menu “new report”. This report is structuring the information relating to the terminated business relationship (reference of the related suspicious activity report (STR), accounts concerned, date of termination, etc.).
As a transitional measure and until the deadline for the implementation of goAML version 5 by the financial intermediaries has been reached, this termination notification of a business relationship can also be made by means of a message sent via the Message Board of the goAML web portal.
Corresponding instructions with detailed information can be found under the "Documents" tab, namely “Instructions for the termination notification pursuant to art. 9b AMLA – message via Message Board” and “Procedure for the termination notification of a business relationship pursuant to art. 9b AMLA – entering a report CANCL/CANCT”. The latter document mainly consists of a new chapter 11 of the user manual (goAML Web – Manual) which is also available under "Documents". The current manual (version 2.0), which has been valid since 1.4.2021, will be replaced from 1.1.2023 by a new version, which will be valid from then on and will include this new eleventh chapter.
- Adjustment to the practice of reporting via goAML valid from 01.04.2021 (PDF, 190 kB, 30.03.2021)
- Fact Sheet Web-Reports (PDF, 196 kB, 07.12.2022)
- goAML Web - Manual (PDF, 4 MB, 07.12.2022)
- Standard XML Reporting - Instructions and Specifications for goAML (PDF, 4 MB, 10.01.2023)
- MROS_goAML-Schema (XSD, 123 kB, 07.12.2022)
- goAML_Transactions_Upload_Schema (XSD, 69 kB, 06.05.2022)
- goAML_Transactions_Upload_Specification (PDF, 1018 kB, 12.09.2022)
- Template for accounts – termination notification pursuant art. 9b AMLA via Message Board (XLSX, 10 kB, 19.09.2022)
- Instructions for the termination notification pursuant to art. 9b AMLA – message via Message Board (PDF, 336 kB, 22.09.2022)
- Procedure for the termination notification of a business relationship pursuant to art. 9b AMLA – entering a report CANCL/CANCT (PDF, 491 kB, 19.10.2022)
- Frequently Asked Questions (FAQ) (PDF, 255 kB, 19.09.2022)
- V-Indicators valid as of 2023 (XLSX, 28 kB, 10.01.2023)
Last modification 07.12.2022