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