Pillar D
Reporting & Monitoring
Catching the transaction patterns that matter, drafting the report, and keeping your recurring compliance obligations on schedule.
Transaction-level red-flag monitoring
Deals are monitored against typologies drawn from FATF and CBUAE guidance on money laundering through real estate. These are patterns that, on their own, don't prove wrongdoing — but that warrant a closer look and, often, a documented reason for proceeding:
Structuring
Payments broken into amounts designed to stay under reporting or scrutiny thresholds.
Third-party payments
Funds for a transaction arriving from a party unconnected to the buyer or the deal.
Rapid resale
A property bought and resold shortly after, with little apparent commercial rationale.
Shell-company buyers
Purchasing entities with opaque ownership, no discernible business activity, or newly formed for the transaction.
Guided SAR/STR drafting
When a red flag warrants escalation, a Suspicious Activity Report (SAR) or Suspicious Transaction Report (STR) needs to capture the specific facts a regulator will assess — not a generic narrative. Our drafting workspace walks the MLRO through a guided template covering the parties involved, the transaction detail, the specific indicators observed, and the supporting documentation, so the report is complete and defensible before it's submitted.
goAML filing-workflow tracking
Once a SAR/STR is drafted, we track it through the filing workflow — drafting, internal review, sign-off, and submission status — so nothing sits half-finished. To be clear about what this service does and does not do: the actual submission of a report on the UAE's goAML portal is, and remains, an action taken by your firm's own designated MLRO on the regulator's system. Compass & Coin tracks and supports the filing workflow leading up to that point; we do not submit reports to the regulator on a client's behalf.
Compliance calendar
Beyond individual filings, an AML program carries recurring obligations that are easy to lose track of once the initial registration is done. We maintain a compliance calendar covering the deadline types below — illustrative of what's tracked, not a live schedule for any particular client:
- Policy manual renewal and annual review
- AML training refreshers for staff
- Independent audit cycles
- Regulator correspondence and response deadlines
Get your reporting workflow in order
We'll review how your firm currently handles red flags, SAR/STR drafting, and filing deadlines, and recommend what to tighten up.
Book a Free AML Scoping Call