goAML OPERATIONAL GUIDELINES

goAML OPERATIONAL
FOR

COOPERATIVES
GUIDELINES
January,
FOR 2024
CO-OPERATIVES
FINANCIAL INTELLIGENCE UNIT
(FIU-NEPAL)
NEPAL RASTRA BANK
0
 Foreword
The core function of an FIU-Nepal is the serving as a national center for the receipt, analysis, and
dissemination of information regarding money laundering and the financing of terrorism. The
reports submitted to FIU-Nepal comprises of Suspicious Transaction Report (STR), Suspicious
Activity Report (SAR) and Threshold Transaction Report (TTR). In order to facilitate reporting
process FIU-Nepal has procured goAML software developed by United Nations Office on Drugs
and Crime (UNODC).

goAML Software has been upgraded to newer 5.2.0 version from previous 4.9.3.0 version. This
amended version has incorporated many new updates and is intended towards enabling the
Reporting Entities to generate and submit properly structured STRs, SARs and TTRs in goAML.
These guidelines are focused more towards clarifying the business logic and practical aspects of
structuring and reporting various types of transactions so that the Securities Companies can report
uniformly in goAML. In addition to this document, FIU-Nepal has issued ‘Web Reporting
Guidelines’ and ‘Standard XML Reporting Instructions and Specification’ as a guidance for XML
and web reporting at goAML.

These guidelines have included definitions and procedures regarding several regulatory reports
and transactions, indicators and attachments that must be submitted in such process. It also
illustrates the necessary information that Securities Companies need to provide in STR, SAR and
TTR, selection of 'From' and 'To' parties, selection of ‘Transaction Mode’ and ‘Funds Type’ for
different types of transaction and additional information that Securities Companies need to provide
for some cases. FAQs segment has also been included to address the most common queries from
the REs.

We may occasionally communicate information as and when required for addressing minor
changes if any and for facilitating the Securities Companies in course of reporting.

I would like to urge all Securities Companies to grasp maximum benefit of these guidelines.
Finally, I extend my sincere thanks to goAML team members Keshav Prasad Rimal, Kamal
Paudel, Ranjana Gotame, Bibesh Pokhrel and Deepak Parajuli who had done the tremendous and
valuable job for this version.

Dirgha Bahadur Rawal

Head/Director, FIU-Nepal

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Table of Contents

A. Key Terminologies .......................................................................................................................6

B. Acronyms/Abbreviations ..............................................................................................................6
1. BACKGROUND AND INTRODUCTION ....................................................................................8
1.1 Background ......................................................................................................................................... 8
1.1.1 The goAML Software System ..................................................................................................... 8
1.1.2 Inherent Risk and shortcomings in paper based/manual reporting procedure ............................. 9
1.1.3 Advantages of using goAML ..................................................................................................... 10
1.1.4 Major challenges faced during implementation of goAML ....................................................... 10
1.1.5 Methods of reporting in goAML system.................................................................................... 11
1.1.6 Report Structure ......................................................................................................................... 13
1.2 Introduction of goAML Operational Guidelines............................................................................... 15
1.2.1 Report Types .............................................................................................................................. 15
1.2.1.1 Threshold Transaction Report (TTR).................................................................................. 15
1.2.1.2 Suspicious Transaction Report (STR)................................................................................. 16
1.2.1.3 Suspicious Activity Report (SAR) ...................................................................................... 16
1.2.2 Guidelines for Reporting Transactions for STR, SAR and TTR ............................................... 17
1.2.3 Providing information in the Transaction node ......................................................................... 17
1.2.3.1 Providing information in the Transaction node > From Party ............................................ 19
1.2.3.2 Providing Information of Conductor................................................................................... 19
1.2.3.3 Providing information in the Transaction node > To Party ................................................ 20
1.2.4 Providing information for ‘My Client’ ...................................................................................... 22
1.2.4.1 In case of Person ................................................................................................................. 22
1.2.4.2 In case of Entity .................................................................................................................. 24
1.2.4.3 In case of Account............................................................................................................... 26
1.2.5 Providing information for ‘Not My Client’ ............................................................................... 28
1.2.5.1 In case of Person ................................................................................................................. 28
1.2.5.2 In case of Entity .................................................................................................................. 29
1.2.5.3 In case of Account............................................................................................................... 29
1.2.6 How to report TTR, STR and SAR in goAML? ........................................................................ 29
1.2.6.1 TTR Reporting .................................................................................................................... 29
1.2.6.2 STR Reporting .................................................................................................................... 30

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 1.2.6.3 SAR Reporting .................................................................................................................... 34
2. VARIOUS SAMPLE CASES ...................................................................................................... 36
2.1 Selection of ‘My Client’ and 'Not My Client’ .................................................................................. 36
3. TRANSLATIONS OF XML ELEMENTS AND CORRESPONDING LABELS IN WEB
INTERFACE .................................................................................................................................. 38
4. DESCRIPTION OF 'TRANSACTION MODE MASTER' AND 'FUNDS TYPE MASTER' ...... 43
4.1 Transaction Mode Master ................................................................................................................. 43
4.2 Funds Type Master ........................................................................................................................... 43
5. MESSAGE BOARD .................................................................................................................... 44
6. SUMMARY OF IMPORTANT POINTS .................................................................................... 44
7. FREQUENTLY ASKED QUESTIONS....................................................................................... 47
Annex 1: Format of Transaction Details ................................................................................................. 55
Annex 2: Report Status ........................................................................................................................... 56
Annex 3: Commonly Made Mistakes in Reporting ................................................................................ 58

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LIST OF FIGURES
Figure 1: goAML implementing countries as of January, 2022 ................................................................... 8
Figure 2: Steps in goAML Software System ................................................................................................ 9
Figure 3: Report Structure in goAML......................................................................................................... 13
Figure 4: Navigation pane of goAML-Web Reporting Portal .................................................................... 29

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Disclaimer

These guidelines are issued by FIU-Nepal by including summary of technical know-hows

to be adopted by Co-operatives Companies while reporting TTR, STR, SAR and
communicating with FIU-Nepal via goAML software. It is not an exhaustive list of steps.

These guidelines cannot be sole evidence of complying with the requirements of the
AML/CFT legal provisions.

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A. Key Terminologies

Natural Person involved in carrying out Transaction (May be same

a) Conductor
as From Party or To Party in most cases)

Drop Down list of Predicate Offences (as per ALPA, 2008). One or
b) Indicators
more indicators shall be chosen while reporting STR/SAR.

c) My Client Person(s) or Entity holding policy in the Co-operatives Company

Person(s) or Entity not holding policy in the Co-operatives

d) Not My Client
Company

Identifies flow of fund in various forms from ‘From’ Party to ‘To’

e) Transaction
Party

B. Acronyms/Abbreviations

ALPA Asset (Money) Laundering Prevention Act, 2008 (with amendments)

AML/CFT Anti-Money Laundering and Combating the Financing of Terrorism
AoA Article of Association
CDD Customer Due Diligence
DNFBPs Designated Non-Financial Businesses and Professions
ECDD Enhanced Customer Due Diligence
FATF Financial Action Task Force
FIU-Nepal Financial Information Unit, Nepal
IBAN International Bank Account Number
ID Identity Document
IPS Interbank Payment System
KYM Know Your Member
LEAs Law Enforcement Agencies

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ML/TF Money Laundering and Terrorist Financing
NRA National Risk Assessment
NRB Nepal Rastra Bank
PAN Permanent Account Number
REs Reporting Entities
SAR Suspicious Activity Report
STR Suspicious Transaction Report
SWIFT Society for Worldwide Interbank Financial Telecommunications
TTR Threshold Transaction Report
UNODC United Nations Office on Drugs and Crime
VAT Value-added Tax
XML Extensible Markup Language

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1. BACKGROUND AND INTRODUCTION
1.1 Background

1.1.1 The goAML Software System

FIU-Nepal has implemented goAML software

system developed by United Nations Office on
Drugs and Crime (UNODC). The goAML system
is the UNODC Software Products for Member States' response to money laundering and terrorist
financing, and is available to Financial Intelligence Units of Member States to support their work.
As of Jan-2024, more than 60 countries have already deployed goAML. In the first phase, it's fully
functional product version is being implemented in A, B & C class Banks and Financial
Institutions. Similarly, Insurance companies started reporting in goAML (Production
Environment) from April 2022 and Remittance Companies from May, 2022. Law enforcement
agencies (Nepal Police, DRI, DMLI, IRD, Customs and CIAA) are also integrated in goAML
system. Furthermore, regulators and supervisors are also integrated in goAML system to get
supervisory access to RE's reporting and integration status. DNFBPs are also being gradually
integrated to use goAML. Now all REs must register in goAML system (Production Environment)
for reporting through Web/XML format of goAML by replacing Paper/CD/Email based manual
reporting.

Figure 1: goAML implementing countries as of October, 2022

Source: UNODC

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goAML helps online receipt of SARs, STRs and TTRs from the REs and analyze such reports in
an automated form. As per the experiences of other counterparts, goAML not only gears up the
capacity of FIU, particularly in its core function like receiving and analyzing information, but also
assists for qualitative analysis. It requires strengthening the technical and analytical skills of FIU
staffs.

The goAML solution is executed in three steps: Collection, Analysis (rule-based analysis, risk-
score and profiling) and Dissemination (escalate to law enforcement and seek feedback). It
provides a facility for the rapid exchange of information between the FIU-Nepal, financial
institutions law enforcement and judicial authorities, while ensuring confidentiality of the data
collected.

COLLECTING ANALYZING DISSEMINATIN

•SAR/STR/TTR •Collating
G
•Intelligence
•Charting reports to LEAs
•Additional
information •Intelligent •Cooperation with
pattern detection other FIUs

Figure 2: Steps in goAML Software System

Source: UNODC

1.1.2 Inherent Risk and shortcomings in paper based/manual reporting procedure

a) Risk of leaking, manipulating or tipping off information while exchanging hard copy document
in various levels and by various personnel involved in the communication channel – sender,
dispatch personnel, carrier, primary receiver etc.
b) Risk of loss, damage or theft while handling the documents in physical form.
c) Procedure and channel for communicating AML/CFT information should be secured and
reliable as recommended by FATF. Since leaking, manipulating or tipping off information is
generally considered serious crimes as per AML/CFT regulations
d) Difficult to manage records and keep statistics of various types of reports received from REs
and domestic cooperation between FIU and LEAs leading to mismatch in statistical data.

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e) Time consuming and receipt/non-receipt of the correspondence needs to be confirmed via
phone call in many cases.

1.1.3 Advantages of using goAML

a) goAML uses secured electronic channel for communication and the information is transferred
in encrypted form so the chances of leaking and manipulating information is minimal.
b) goAML can be used both for receiving reports from REs and disseminating information to
LEAs while maintaining the confidentiality and integrity of the information
c) The information can be directly sent and received by the end parties without the involvement
of third parties like messenger and carriers.
d) Communication through goAML is simple, easy and fast (similar to sending email/filling web
form)
e) No need to purchase or install new software at REs/LEAs end (software is already procured
and installed by FIU-Nepal) although REs may require middleware for generating XML
reports
f) REs/LEAs just require internet connectivity for reaching the goAML server/website
g) LEA can provide feedback on the disseminated information to FIU-Nepal along with Asset
Confiscation and detailed conviction information (including number of persons convicted)
h) International co-operation to be made in co-ordination of FIU e.g. EGMONT group, APG, etc.,
can be done efficiently
i) Statistics of various types of reports submitted by REs and dissemination, feedback, domestic
and international co-operation can be maintained and obtained easily.

1.1.4 Major challenges faced during implementation of goAML

The major challenges faced during the implementation of goAML are:

a) Customizing goAML to match the data fields and reporting requirement for different type of
REs
b) Lack of necessary data with the REs (lack of updated KYM related documents)
c) Lack of digitized data with the REs (documents stored as scanned copy)

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d) Lack of necessary data fields in enterprise application of REs as per data requirement in
goAML
e) Challenges in updating KYM related documents of clients and digitizing data
f) Challenges in developing middleware for generating XML files as per goAML schema
g) Challenges in mapping available data from enterprise application of REs to goAML XML file
format
h) Lack of comprehensive goAML related training to FIU staffs
i) Frequent issues faced in goAML system hardware and software due to power failure, physical
migration of hardware to various locations etc. causing unprecedented downtime of goAML
system

1.1.5 Methods of reporting in goAML system

Co-operatives Companies can submit reports in goAML system in the following ways:

A. Web Report
B. XML Report

A. Web Report: SAR/STR/TTR reports in goAML system can be submitted by typing manually
in web form. There are mandatory and non-mandatory fields in goAML. The mandatory fields
which are marked by asterisk sign (*) should be filled. The non-mandatory fields or optional fields
can be leave as blank. Certain fields which are not marked as mandatory in goAML can also be
provided as per operational guidelines issued by FIU-Nepal. While filling in the web form, there
are other different types of cascading web forms that should be saved one after another before
submitting. If there are errors in the form (shown with red color), that should be revisited and
corrected accordingly.

B. XML Report: An XML file is an extensible markup language file, and it is used to structure
data for storage and transport. In an XML file, there are both tags and text. The tags provide the
structure to the data. The text in the file that you wish to store is surrounded by these tags, which
adhere to specific syntax guidelines. At its core, an XML file is a standard text file that utilizes
customized tags, to describe the structure of the document and how it should be stored and
transported.

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An XML schema is a description of a type of XML document, typically expressed in terms of
constraints on the structure and content of documents of that type, above and beyond the basic
syntactical constraints imposed by XML itself.

The XML file suitable with goAML can be generated through middleware software. Middleware
software takes input as raw data from core system of REs, or similar software in Co-operatives,
securities and other) and generate XML file as output. It validates the XML file through goAML
XML validator. This option is also available in goAML website. All the validated XML files can
be zipped and upload in bulk through XML upload.

XML reporting is appropriate in case of large number of reports than web based reporting.
Individual transaction should type manually one by one and save to report threshold transaction in
web based reporting, which is quite time consuming process. Once the XML file is generated
which includes all the transactions of specific report and submitted in our system and it is easy
process.

There are two types of validation in goAML which are initial schema level validation and business
rule or logical validation. The initial schema level validation validates the report file based on
available XML schema in goAML system and business rule or logical validation validates report
based on available XML rejection rule in goAML system. After the pass of all business rules the
report status is processed and saved in goAML database system.

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1.1.6 Report Structure

Report Type

Transaction

From Party Conductor To Party

My My
Client Not My Client Not My Client
Client

Person,
Person, Entity, Person, Entity, Person, Entity,
Entity,
Account Account Account
Account

Figure 3: Report Structure in goAML

a. Report Type: The report types in goAML are Suspicious Activity Report (SAR), Suspicious
Transaction Report (STR) and Threshold Transaction Report (TTR).

b. Transaction: Threshold transaction of person or account or entity should be reported while

reporting TTR and suspicious transaction of specific party should be reported during STR
reporting. At least one of the suspicious transactions should be provided while reporting STR.

c. From Party: Multi party and Bi-Party transaction features of goAML software system enable
us to capture the information of party type. Bi-party means two party. Currently, both Bi-party and
Multi party transaction features are enabled in our system. REs should provide transaction
information accordingly while reporting. The two party type are 'from party' and 'to party'. 'from
party' is also called source party. The party type information depends upon the flow of currency.
For example, if a person deposits premium, the 'from party' is person and REs should provide the

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person information in 'from party' node. The different cases are explained in goAML operational
manual issued by FIU-Nepal.

d. Conductor: Conductor is always natural person. A person who carries transaction on behalf of
others or self. The Information regarding natural person should be provided while reporting and it
plays vital role while tracking the suspect person.

e. To party: Another party type is 'to party' and also called destination party. For example, if a
person deposits premium in his/her account then 'to party' is Account>My Client, so policy details
should be provided in 'Account' node. The different cases are explained in goAML operational
manual issued by FIU-Nepal.

f. My Client: From the point of view of REs, the party (Individual, entity) whose account
information presented in their institutions are categorized as 'my client'. REs should provide detail
information of my client inside 'my client' node.

g. Not My Client: If transaction was carried out by an individual person or account in Co-
operatives company or other REs and the information regarding such person or account or entity
is not available with them, they can categorize such information as not my client. The minimum
information of not my client should be provided under 'not my client' node.

h. Person: Depending upon the transaction scenario, if a person who involves in transaction or
whose account information is available with REs, they should provide detail information of person
while reporting in goAML software system. If the person is not my client, then minimum
information can be provided.

i. Account: Depending upon the transaction scenario, if the account information of natural person
or entity is available with REs, they should provide detail information of the account while
reporting in goAML. If account is not my client, then minimum information can be provided.

j. Entity: Depending upon the transaction scenario, if account information of the organization or
entity is available with REs, they should provide detail information of the account while reporting
in goAML software system. If account is not my client, the minimum information can be provided.

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1.2 Introduction of goAML Operational Guidelines

These guidelines are issued for Co-operatives Companies as per power conferred under Section
7S. (3), 10 (1) (h) and 10A. (2) of ALPA, 2008. These guidelines help in reporting of STR, SAR
and TTR via goAML Software.

There are several reporting fields in goAML software such as Report Types and its sub-categories,
Transaction Mode, Indicators, Attachments, From Parties and To Parties, Funds type etc. These
guidelines will highlight the basic definition and its use in goAML. Several scenarios and cases
mentioned in these guidelines will help Co-operatives Companies in reporting.

This version of goAML Operational Guidelines includes SAR Reporting, STR and TTR,
Attachments required in STR/SAR etc. There is also format of Transaction Details in annexure
and it also contains several fields and process that is being introduced in goAML.

1.2.1 Report Types

1.2.1.1 Threshold Transaction Report (TTR)

TTR is a report that Co-operatives are required to submit to FIU-Nepal for transactions; if it
exceeds prescribed threshold limit. The TTR limit for various reporting entities is different as per
their nature and scope (See 'TTR Guidelines' issued by FIU-Nepal and 'AML/CFT Directive'
issued by Department of Co-operatives).

TTRs are very important to develop the data of customers'/clients' profile for future use in case
such transactions happen to be connected with money laundering and terrorist financing offences.
TTRs also help to form a link chart during the analysis of a STR and help the investigator/analyst
to find the criminal elements involved in the transactions and convert the financial information
into financial intelligence by adding value in it.

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1.2.1.2 Suspicious Transaction Report (STR)

As per Section 7(S)(1) of ALPA 2008, Reporting Entity shall make a suspicious transaction report
to the FIU within three days as far as possible if they find following circumstances in relation to
any customer, transaction or property.

a) If it suspects or has reasonable grounds to suspect that if the property is related to ML/TF or
other offence, or
b) If it suspects or has reasonable grounds to suspect that the property is related or linked to, or
is to be used for, terrorism, terrorist, terrorist acts or by terrorist organization or those who
finance terrorism.

STR include detailed information about transactions that are suspected violations of law or appear
to be suspicious/ doubtful or arouse suspicion. The goal of STR filing is to help FIU-Nepal to
identify individuals, groups and organizations involved in predicate offences declared in ALPA,
2008. In many instances, STRs have been instrumental in enabling law enforcement to initiate or
supplement major money laundering or terrorist financing investigations and other criminal cases.

1.2.1.3 Suspicious Activity Report (SAR)

As per Section 7(S)(2) of ALPA 2008, Reporting entity shall also submit the report of attempted
transactions or activity to FIU as mentioned under sub-section (1).
Suspicious Activity (SA) arises from suspicion relating to general behavior of the person in
question which creates the knowledge or belief that he or she may be involved in illegal activities
out of which proceeds might be generated. Any suspicious attempted transaction also falls in this
category. For example:
 A Co-operatives refuses to accept a transaction because the client refuses to provide
identification, source of fund, contact details etc. as requested.
 Activities related to Identity Theft.
 Information on fake document issued by any organization.
 Attempted Fraudulent activities
 Any other attempted transactions.

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1.2.2 Guidelines for Reporting Transactions for STR, SAR and TTR

Transaction is the most important component of reporting in goAML since it includes all the
necessary details of cash flow and involved parties. The analysis of submitted reports is primarily
dependent upon the details provided within the Transaction node. The Co-operatives should
properly understand the business logic behind any transaction and provide all the necessary and
available information while reporting in goAML.
Since the details that need to be provided inside Transaction node are same for TTR and STR, so
this topic will provide guidance for providing information properly inside the Transaction node
for both report types. While TTRs are usually generated by system with existing data and bound
to mandatory fields, we expect some additional data and manual inputs by the Co-operatives
Companies in reporting STR and SAR such as Reason, Attachments, Indicators, Transaction
Comments and any other relevant information wherever possible.
1.2.3 Providing information in the Transaction node

Transaction Node

SN Fields Description Mandatory/Optional Remarks

1 Transaction number Unique value to identify Mandatory If Unique transaction number is
Transaction not available, use the generate
button to the right.
2 Internal Reference Unique value to refer to Optional Maybe provided same as
Number the Transaction Transaction number
3 Transaction Mode Identify the Mode of Mandatory Refer to Lookup Table and
Transaction sample cases
4 Transaction Comment Information about the Optional, provide only if Information has to be provided
Transaction mode the Transaction Mode is if Transaction Mode is ‘Others’
'Others'.
5 Local Amount The amount of Mandatory The amount of the transaction
transaction in NPR in Nepali rupees. Provide
without comma, may have
decimal value. (Use zero if
there was no transaction)

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6 Date Date of Transaction Mandatory Provide the value date of
transaction and not posting,
reporting or any other date
7 Late Deposit Specify whether Optional Click yes if the amount is
transaction is a regular received in late hours. But
transaction or Late account credited only in the
Deposit following day also enter posting
8 Posting Date Specify Posting Date if Optional date if the late deposit is made.
'Late Deposit ' is
checked
9 Teller Teller who conducted Optional but preferred Provide Full name and or
the transaction Employee/Teller Code
10 Authorized Person who authorized Optional but preferred Provide Full name and or
the transaction Employee/Teller Code
11 Location Address where the Mandatory Provide specific location
transaction was carried information and not codes or
out (Branch name or short forms and must be
Place) consistent across all STRs.
12 Description Description/Narration of Optional but preferred Description of Transaction
Transaction
13 Comments Analytical Comment on Optional but preferred for
the Trend/Suspicion of STR
the Transaction i.e.
suspicion of involvement
in a particular predicate
offence

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1.2.3.1 Providing information in the Transaction node > From Party

Transaction Node – From Party Sub node (From Type)

SN Fields Description Mandatory/Optional Remarks
1 From Funds Specifies nature of fund Mandatory Refer to Lookup Table and
Type flow from ‘From’ Party Sample cases
2 Source of Fund Source of fund for Optional Example Sale of assets,
Transaction Borrowing, Business Income,
Salary etc. as declared by
customer
3 Country Country of origination Mandatory
of transaction
4 Foreign Provide if foreign Optional but mandatory for Need to provide Currency code,
Currency currency is involved in cases where foreign currency Amount and Exchange rate for
transaction involved the day the transaction was
carried out
5 Conductor Natural Person present Optional, but need to provide for Refer to various cases when
while carrying out the all applicable cases. conductor information need to
transaction be provided

1.2.3.2 Providing Information of Conductor

Conductor in the context of goAML refers to the natural person present while carrying out the
transaction. Conductor may be same as ‘From Party – Person’ or ‘To party – Person’ in most of
the cases while may be different in some cases. Same information should be provided for both
Conductor and ‘From’ or ‘To’ party if they are identified to be the same.

If Conductor is identified as ‘My Client’ (Member of the Cooperative), then complete information
of the Conductor should be provided including Personal details, Address, ID and Contact details
for all applicable cases. The information to be collected like ID details, Phone number for ‘Not
My Client’ and Source of Fund, Purpose of Transaction for some specific cases should be
identified by Co-operatives Companies and collected accordingly. If ID details and Contact
number is required, then such information needs to be collected on behalf of Conductor rather than
the beneficiary if Conductor is different from the beneficiary.

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1.2.3.3 Providing information in the Transaction node > To Party

Transaction Node – To Party Sub-node (To Type)

SN Fields Description Mandatory/Optional Remarks
1 To Funds Specifies nature of Mandatory Refer to Lookup Table and Sample
Type fund flow to ‘To cases
Party’
2 Purpose of Purpose of Optional As declared by customer
Transaction Transaction
3 Country Country of destination Mandatory Default to Nepal
of transaction
4 Foreign Provide if foreign Optional but mandatory if Need to provide Currency code,
Currency currency is involved foreign currency is Amount and Exchange rate for the
in transaction involved. day the transaction was carried out

Information to be provided for To Party> Account>My Client

Node – Account
SN Fields Description Mandatory/Optional Remarks
1 Account Number Member account Mandatory Provide Account Number
Number
2 Name Account Holder Name Mandatory Provide name exactly as per
account
3 Institution Name Name of Co- Mandatory Provide the name exactly as
operatives per registration in goAML
4 Branch Branch where the Mandatory Provide branch name/location
account is opened and not code or short name
5 Non-Banking Specify whether the Optional ‘Yes/True’ for non - BFIs
Institution Reporting Entity
where the account is
held is BFI or not
6 BIC/ SWIFT Specify Institution Mandatory Not Applicable (NA) for Co-
code for an institution operatives companies
7 Account Type Type of Account – Mandatory Example : Savings
Refer to Lookup Table

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 Node – Account
SN Fields Description Mandatory/Optional Remarks
8 Status Code Current status of the Mandatory Example: Active, dormant, etc.
Account – Refer to
Lookup Table
9 Currency Code Account Currency Mandatory For Nepalese currency: NPR.
Code
10 Beneficiary Provide name of Optional but preferred if
Beneficial owner of beneficiary is different
the account from the account holder
11 Client’s Risk High Risk, Medium Optional Optional but preferred if
Grade (IBAN in Risk, Low Risk and identified
XML) other Risk category
12 Client number Unique Client number Optional
provided to Account
holder by the Co-
operatives
13 Opened Date of Account Mandatory
Opening
14 Closed Date when the Optional Provide closing date if the
Account was closed account is closed
15 Balance Select ‘Yes’ and Mandatory Balance in the account after
provide balance in all transaction
cases
16 Date of Balance Balance should match Mandatory Balance date
the Date of Balance
for reported
transaction
17 Beneficiary Any further Optional Any useful information if
Comment information about the beneficiary is found different
beneficiary, useful in from account holder during
case of STR CDD, ECDD.

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 Node – Account
SN Fields Description Mandatory/Optional Remarks
18 Comments Any other relevant Optional, but have to
information about the provide any relevent
Account and in cases Information
where Lookup values
in Account node are
selected as ‘Others’

 Common scenario for additional information in case of Co-operatives

How should TTR of multiple accounts of same individual/entity be reported?

In case of multiple account of same individual/entity following procedures needs to be
followed;
 UNIQUE ID of individual/entity shall be used as 'Account Number' ('To My
Client>Account>Account Number) instead of individual number of different account
type.
 Total number of existing account of each UNIQUE ID shall be mentioned in
'Description' (Transaction > Description).

1.2.4 Providing information for ‘My Client’

While reporting any transaction involving ‘My Client’ in either ‘From’, ‘Conductor’ or ‘To’ party,
the Co-operatives should provide all available information in proper fields as provided by the client
in KYM related documents. It’s up to the Co-operatives to implement methods to identity whether
a party involved in a transaction is 'My Client'.

The Co-operatives should also ensure that the information of Client is updated and complete as
per exiting regulations and by means of CDD, ODD and ECDD.

1.2.4.1 In case of Person

While reporting transaction that involves a natural person who is their Client, Co-operatives should
provide all the available details of the person that they have collected/updated as per existing

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regulations and KYM guidelines like Personal details, Address, Contact details, Identification,
Occupation, Employer details, PAN and Source of income. Such details should be provided in
proper fields as specified in goAML Schema.

The details of the involved Person should be provided in all applicable cases like:

 From My Client – Person

 To My Client > Account > Related Persons > Person
 While providing the details of the Related Persons for accounts, Reporting Entities should
provide same details as ‘My Client’ – Person that includes Personal details, Address,

Note: If a same person is involved as all three parties in a transaction for example Person XYZ
deposits 3 Lakhs to his own account then all the specified details of the Person XYZ should be
provided in ‘From’, ‘Conductor’ and ‘To’ Party fields.

Contact number, Identification and other available information.

Information to be provided for Person – ‘My Client’ are:

Node Person
SN Fields Description Mandatory/Optional Remarks
1 First Name Name of customer Mandatory
2 Middle Name Optional
3 Last Name Last Name of the customer Mandatory
4 Prefix Optional Do not fill any
information in prefix
5 Birth Date Date of Birth of the Mandatory Provide as specified
customer in valid document
6 Father’s Name Name of Father of the Mandatory for ‘My Client’ Provide as specified
customer in valid document
7 Mother’s Name Name of Mother of the Optional
customer
8 Spouse Name Name of Mother of the Optional
customer
9 Citizenship Mandatory for ‘My Client’
Number

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 Node Person
SN Fields Description Mandatory/Optional Remarks
10 ID Number Document other than Mandatory if ID is other Example : National
Citizenship than citizenship ID number
11 Nationality 1 Nationality 1 Mandatory
12 Nationality 2 Optional
13 Residence Name of the Country Mandatory
14 Occupation Additional information Mandatory Nepal
about the Entity
15 PAN PAN Number Optional, Provide if
available
16 Grandfather’s Name of the grandfather of Optional, Provide if
Name the person available
17 Source of Income Optional
18 Phones Telephone Number Optional, Provide if
available
29 Address Address of the person Mandatory
20 Identification Identification Documents Mandatory Provide information
of the provided
document of the
person
21 Emails Email Address of the Optional, Provide if
person available
22 Comments Additional Information Optional, include if there is
about person any

1.2.4.2 In case of Entity

If an Entity which is the client of the Co-operatives is involved in either 'From' or 'To' Party in a
transaction without direct involvement of its account like cash deposit by Entity in any other
account, then following information should be provided:

 My Client > Entity Details

 My Client > Entity > Related Persons Details

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Information to be provided for Entity – ‘My Client’ are:

Node Entity
SN Fields Description Mandatory/Optional Remarks
1 Name Name of the Entity as per Mandatory Provide exactly as per
Registration Certificate Registration Certificate
2 Commercial Popular commercial name Optional Provide if such information
Name besides actual name as per is available
AoA and MoA
3 Registration Identifies the type of Entity Mandatory for ‘My Refer to Lookup Table
Legal Form Client’
4 Business Nature of business the Entity Mandatory for ‘My Provide specific business
is involved as per AoA and Client’ information
MoA
5 Registration Registration Number of Entity Mandatory for ‘My Provide information as per
Number as per Registration Certificate Client’ Registration Certificate
6 Registration Date of registration as per Mandatory for ‘My
Date Registration Certificate Client’
7 Registering Authority under which the Mandatory for ‘My Authority under which the
Authority Entity is registered Client’ Entity has been
registered/licensed to
operate
8 Registration Country where the Entity is Mandatory for ‘My
Country Code registered Client’
9 Email Official Email address of Provide if available
Entity
10 URL Official Website of the Entity Provide if available
11 PAN/VAT PAN/VAT Number Mandatory for Entities
Number having PAN/VAT
12 PAN/VAT PAN/VAT Registration Date Mandatory for Entities
Registration having PAN/VAT
Date

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 Node Entity
SN Fields Description Mandatory/Optional Remarks
13 Comments Additional information about Mandatory if Information about the
the Entity Registration Legal Corporate Shareholders can
From is selected as also be specified in this
‘Others’ and field
Registration Country
Code is selected as
‘Unknown’

Along with Entity details, other information that should be provided for Entity - ‘My Client’
are:
a) Registered Address of Entity
b) Telephone/Contact Information of Entity
c) Available information of Director(s) of the Entity that should include Director Role,
Personal details, Address, Contact number, Identification and other available information.

Notes:
i. For Entities that do not require to be registered or do not have registration number – Provide ‘Not
Applicable’ in 'Registration Number' field
ii. Entities for which PAN/VAT Number is not required to be registered – Provide ‘Not Applicable’ in
'PAN/VAT Number' field
iii. For Joint Venture that do not require to be registered – Provide ‘Not Applicable’ in 'Registration
Number' field and PAN/VAT Number of Joint Venture should be provided in 'PAN/VAT Number'
field.

In case if Entity’s shareholder is another Entity i.e Corporate Shareholder, such information can be
provided in Related Entity node with Name of Entity and Name of major Shareholders and/or Directors.

1.2.4.3 In case of Account

If an account of ‘My Client’ – whether Individual, Minor, Entity, etc. is involved during a
transaction, Co-operatives should provide following details of the account along with the Related
Persons (Signatory(ies)) of the related account as per account opening form and KYM related
documents.

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 Node – Account
SN Fields Description Mandatory/Optional Remarks
1 Account Number Account number Mandatory Provide Number of the client
2 Name Account Name Optional but preferred Provide name exactly as per
account name
3 Institution Name Name of institution Mandatory Provide the name exactly as
where account is held per registration in goAML
4 Branch Branch where the Optional Provide branch name/location
account is opened and not code or short name
5 Non-Banking Specify whether the Optional Choose ‘No’/’False’ for BFIs,
Institution? Reporting Entity ‘Yes/True’ for non - BFIs
where the account is
held is BFI or not
6 Code or SWIFT Specify Institution Mandatory Provide NA if unavailable
code for an institution
7 Account Type Type of Account – Optional
Refer to Lookup Table
8 Status Code Current status of the Optional
Account – Refer to
Lookup Table
9 Currency Code Account Currency Optional
Code
10 Beneficiary Provide name of Optional but preferred if
Beneficial owner of beneficiary is different
the account from the account holder
11 Client’s Risk High Risk, Low Risk Optional
Grade (IBAN in and other Risk
XML) category
12 Client number Unique Client number Optional
provided to Account
holder by the Co-
operatives
13 Opened Date of Account Optional
Opening
14 Closed Date when the account Optional Provide closing date if the
was closed account is closed

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 Node – Account
SN Fields Description Mandatory/Optional Remarks
15 Balance Select ‘Yes’ and Optional Amount paid till date
provide balance in all
cases
16 Date of Balance Balance should match Optional
the Date of Balance
for reported
transaction
17 Beneficiary Any further Optional Any useful information if
Comment information about the beneficiary is found out to be
beneficiary, useful in different from account holder
case of STR during CDD, ECDD
18 Comments Any other relevant Optional, but have to
information about the provide any relevent
Account and in cases Information.
where Lookup values
in Account node are
selected as ‘Others’

1.2.5 Providing information for ‘Not My Client’

If any Person, Account or Entity which is not the client of the Co-operatives is involved in either
'From' or 'Conductor' in a transaction, detailed information about such parties may not be available.
Although in such cases, Co-operatives need to provide minimum available information and some
additional information for some cases as per existing regulations which are mentioned below.

1.2.5.1 In case of Person

If any person who is not the client of Co-operatives is involved in any transaction in either ‘From’,
‘Conductor’ or ‘To’ Party, then minimum required details is the Name of the person and Contact
number. If Contact number is not available, this field may be left blank.

Applicable to cases like

 From ‘Not My Client’ - Person

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  Conductor – ‘Not My Client’

1.2.5.2 In case of Entity

If any Entity which is not the client of a Co-operatives is involved in either ‘From’ or ‘To’ Party
in a transaction for cases like Cheque/Cash Deposit by an Entity, Cheque Payment in the name of
Entity then the minimum information the Co-operatives need to provide is the 'Name' of the
Entity. Additional information like ‘Source of Fund’, ‘Purpose of Transaction’ and Conductor
Identification and Contact number should be provided similar to that in case of Person – ‘Not My
Client’ wherever applicable.

1.2.5.3 In case of Account

If an account of the BFIs is involved in either ‘From’ Party in a transaction for the cases like IPS,
Cheque, etc.; then the Mandatory information to be provided for ‘Not My Client’ – Account are
'From Funds Type', ‘Account Number’, ‘Institution name' and ‘Institution code or SWIFT code’.
Account Name and other information should be provided if it is known.

1.2.6 How to report TTR, STR and SAR in goAML?

1.2.6.1 TTR Reporting

A) Selection of TTR Report Types

TTR Reports shall be submitted by

selecting report type 'Threshold
Transaction Report'.

Figure 4: Navigation pane of goAML-Web Reporting

Portal

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B) Parts to be included in TTR Report

Reporting of TTR must include:

a) TTR body ('Reason field': Not Required, 'Suspicious Amount' field: Not Required)
b) Transactions
Notes:
 'Indicators' and 'Attachments' are not required in TTR reports.
 Refer 'TTR Guidelines' for further details.

1.2.6.2 STR Reporting

A) Selection of STR Report Types

STR Reports shall be submitted by selecting report type 'Suspicious Transaction Report'

B) Parts to be included in STR Report

Reporting of STR must include:

a) STR body ('Reason field': Required, 'Suspicious Amount' field: Required)
b) Attachments
c) Indicators
d) Transactions

C) Information Required in 'Reason' field and 'Total Suspicious Amount' field for STR

i) 'Reason' field
Co-operatives should perform preliminary analysis at their end regarding relevant information
and details as to why the reported transactions are suspicious. Also some information which are
important but cannot be accommodated in the goAML data fields should be provided in the
reason field.

Emphasized: Such information should be provided in structured form in the reason field and
should include but not limited to:
a) Name of the Person/entity(suspicious)
b) Summary of Suspicious activities

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 c) Analysis or Examination
d) Possible linkage
e) Suspected Beneficiary
f) Occupation / Business in case of Entity
g) Estimated Yearly Income
h) Linked Persons/Accounts
i) Other relevant information
j) Person and Transaction Tree or Map (May be provided as attachment)

Notes:
 All above 'topics' must be mentioned in reason field. If any of above data is not
applicable, please mention 'N/A' in such cases.
 If added information is to be given in already submitted STR/SAR, new STR/SAR
must be submitted but previous submission must be mentioned in reason field
(under 'other relevant information' topic).

ii) 'Total Suspicious Amount' field

Co-operatives should provide Total Estimated Suspicious Amount (Value) involved in
suspicious transaction. Total amount may be different from particular transaction. It can be
estimated by analyzing particular transaction or series of transactions or by preliminary
analysis/judgement. (In XML, use 'report_action' for this field).

D) Attachments/Additional Information required for reporting STR

While reporting STR, Co-operatives Companies should report suspicious transactions in Web or
in XML format and provide the following documents along with the STR. Co-operatives
Companies can attach files directly while submitting Web Report. To upload attachments along
with the XML files, it is required that the XML file and attachments related with that XML file be
placed in the same folder and the folder needs to be zipped and uploaded.

i) In case of Person
a) Updated KYM related documents

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 b) Photo attached ID card (Issued by Government Authority)
c) Statement from date of account opened (in excel format) of Suspicious Customer and Other
related accounts
d) The summary of transaction details of last 5 years (in excel format, as specified in
Annexure 4 of AML/CFT related directive issued by Department of Cooperatives)
e) Person and Transaction Tree or Map (optional)
f) Related/Adverse media news/reports and other relevant documents if any

ii) In case of Entity

a) Registration Certificate
b) PAN/VAT Certificate
c) Updated KYM related documents of Entity, its Director(s) and Signatory(ies)
d) Photo attached ID card of Director(s) and Signatory (ies)
e) Statement from date of account opened (in excel format) of Suspicious Customer and Other
related accounts
f) The summary of transaction details of last 5 years (in excel format, as specified in
Annexure 4 of AML/CFT related directive issued by Department of Cooperatives)
g) Person and Transaction Tree or Map (optional)
h) Related/Adverse media news/reports and other relevant documents if any

Note:
 For Entities that do not require to be registered, registration certificate or PAN/VAT
certificate may not be provided but reason for the same must be mentioned in reason field.

E) Indicators for STR Reporting

Each STR report must select at least one Indicator from given drop down list of Predicate Offences
(as per ALPA, 2008). One or more indicators shall be chosen while reporting STR. List of
Indicators are as below:
SN Code Indicators
1 AMCR Ancient monument conservation related
2 OJ Any kinds of sexual exploitation including the children

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 3 BM Black marketing, consumer protection, competition, supply
4 CIM Citizenship, immigration and passport
5 CBA Communication, broadcasting, advertising related
6 OA Corruption and bribery
7 ON Counterfeiting and piracy of products
8 OM Counterfeiting of coin and currency
9 DAT Disruptive (terrorist) act and terrorism
10 ELEC Election related
11 OO Environmental Crime
12 OS Extortion
13 FPC Firm, partnership, company, association related
14 FNW Forest, National park and wild animals related crime
15 OT Forgery
16 OC Fraud
17 OK Illicit trafficking in arms and ammunition
18 OB Illicit trafficking in narcotic drugs and psychotropic substances
19 OL Illicit trafficking in stolen and other goods
20 OV Insider Dealing and Market Manipulation in securities and commodities
21 OQ Kidnapping, illegal restraint, hostage taking
22 TF Lottery, gambling, donation related
Money, banking, finance, foreign exchange, negotiable instruments, Co-operatives,
23 BFI cooperatives related
24 OP Murder and grievous bodily injury
25 OE Participation in an organized crime and racketeering
26 OU Piracy
27 REP Real estate and property related
28 SMG Smuggling (including custom)
29 OG Tax (including direct and indirect)
30 OR Theft or robbery
31 OI Trafficking in person and migrant smuggling
32 TEHMF Transportation, education, health, medicine, foreign employment related

Note: While reporting STR/SAR, if any particular offence(s) cannot be linked or if source of fund is not
clear, then report should mention 'Money Laundering' as an offence/indicator, as mentioned below:
SN Code Indicator
33 OD Money laundering

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1.2.6.3 SAR Reporting

A) Selection of SAR Report Type

SAR Reports can be submitted by selecting 'SAR' report type in goAML.

B) Parts to be included in SAR Report

Reporting of SAR must include:

a) SAR body ('Reason field': Required, 'Suspicious Amount' field: Required)
b) Attachments
c) Indicators
d) Activity (Required to provide details, either of 'Account' or 'Person' or 'Entity')

C) Information Required in 'Reason' field and 'Suspicious Amount' field for SAR

i) 'Reason' field
Co-operatives should do preliminary analysis before reporting SAR. Also some information
which are important but cannot be accommodated in the goAML data fields should be provided
in the reason field. Co-operatives required to provide complete available information in
'reason field' if available.
Emphasized: Such information should be provided in structured form in the reason field
and should include (If applicable) but not limited to list mentioned in Point 1.2.6.2 (C) (i).

ii) 'Total Suspicious Amount' field

Co-operatives should provide Total Estimated Suspicious Amount (Value) involved in
suspicious activity. It can be estimated by analyzing attempted transaction(s) or other activities
or by preliminary analysis/judgement. (In XML, use 'report_action' for this field).

D) Attachments/Additional Information required for reporting SAR

While reporting SAR, Co-operatives should report suspicious activities in Web or in XML format
and provide the following documents (If applicable) along with the SAR. Co-operatives can attach
files directly while submitting Web Report. To upload attachments along with the XML files, it is

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required that the XML file and attachments related with that XML file be placed in the same folder
and the folder needs to be zipped and uploaded.

i) In case of Person
 Same as 1.2.6.2 (D) (i)
ii) In case of Entity
 Same as 1.2.6.2 (D) (ii)
Note:
 Documents mentioned in 1.2.6.2 (D) (i) or 1.2.6.2 (D) (ii) must be provided in case of
availability while reporting SAR.

E) Indicators for SAR Reporting

Each SAR report must select at least one Indicator from given drop down list of Predicate Offences
(as per ALPA, 2008). One or more indicators shall be chosen while reporting SAR. List of
Indicators are same as mentioned in 1.2.6.2 (E).

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2. VARIOUS SAMPLE CASES

The following tables illustrate various practical cases of transactions that commonly occur in Co-
operatives Sector that the Co-operatives have to report as TTRs and STRs/SARs. Majority of the
probable cases have been consolidated to clarify the business logics behind them and to specify
proper values from Lookup Tables. Still, there might be some cases left out that may have to be
reported as per existing regulations. In such situation, the Co-operatives need to make rational
decision based on similar cases and try to report transactions logically in proper format in goAML.

2.1 Selection of ‘My Client’ and 'Not My Client’

S. Sample Case Transaction From From To Type To Funds Type

No. Type Funds
Mode
Type

1 Person/Entity In-Branch/ Person/ Cash Account (My- Deposit

Deposits Cash at Different Entity (My- Client)
account maintained Branch Client)
in same
Branch/Different
Branch of
Cooperatives

2 Person/Entity In-Branch/ Account Cheque Account (My- Deposit

Deposits Cheque of Different (BFIs Client)
BFIs at account Branch account
maintained in same details)
Branch/Different
Branch of
Cooperatives

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 3 Person/Entity In-Branch/ Account Cheque Person/Entity Cash
Withdraws Cash Different (My- (My-Client)
using Cheque or Branch Client)
Withdrawal slip
from account
Maintained in same
Branch of
Cooperatives

4 Online deposit by Electronic Person Transfer Account (My- Transfer Receive

member on Transfer (My-Client) Payment Client)*
Cooperatives
account at BFIs

5 Online transfer Electronic Account Transfer Account (My- Transfer Receive

from one member Transfer (My-Client) Payment Client)
Account to another
member Account

* Account details of respective member.

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3. TRANSLATIONS OF XML ELEMENTS AND CORRESPONDING LABELS IN
WEB INTERFACE

While submitting reports in XML format, Co-operatives need to generate valid XML files by
properly structuring and formatting the XML elements and tags in accordance with the latest
goAML XML Schema. Some elements in the XML schema have been adjusted according to
context and requirement. Fields corresponding to such XML elements can be seen translated in
the Web but not in the XML schema as per goAML architecture. While most of the XML elements
have their usual meaning as displayed in the Web, some appear slightly different or have been
modified as per our requirement. The list of such XML elements is mentioned as follows and
corresponding relevant information should be provided in such fields. The Mandatory or Non-
Mandatory Requirement of data for ‘My Client’ and ‘Not My Client’ has also been mentioned in
the table

Mandatory or Non-
Corresponding Remarks
Category/ XML Schema Mandatory
S.N. Label in Web
Nodes Elements/Tags My Client Not My
Interface
Client
transactionnumber Number Mandatory Mandatory
internal_ref_number Internal Optional Optional
Reference
Number
amount_local Local Amount Mandatory Mandatory
transmode_code Transaction Mandatory Mandatory
Mode
transmode_comment Transaction
1 Transaction Comment
date_transaction Date Mandatory Mandatory
teller Teller
authorized Authorized
late_deposit Late Deposit
value_date Value Date
date_posting Posting Date Mandatory if
Late Deposit
TRUE

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 Mandatory or Non-
Corresponding Remarks
Category/ XML Schema Mandatory
S.N. Label in Web
Nodes Elements/Tags My Client Not My
Interface
Client
transaction_location Location Mandatory Mandatory
transaction_description Description

comments Comments
from_funds_code From Funds Type Mandatory Mandatory

from_country Country Mandatory Mandatory

2 From Party
from_funds_comment Source of Fund Mandatory for
specified
cases
to_funds_code To Funds Type Mandatory Mandatory
to_country Country Mandatory Mandatory
3 To Party to_funds_comment Purpose of Mandatory for
Transaction specified
cases
first_name First Name Mandatory Mandatory
middle_name Midle Name
last_name Last Name Mandatory Mandatory
birthdate Birth Date Mandatory
gender Gender Mandatory
prefix prefix Is not used
birth_place Father’s Name Mandatory
mothers_name Mother’s Name
4 Person alias Spouse
ssn Citizenship No. Mandatory
id_number Id Number
nationality1 Nationality 1 Mandatory
nationality2 Nationality 2
nationality3 Nationality 3
residence Residence Mandatory
occupation Occupation Mandatory
employer_name Employer Name

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 Mandatory or Non-
Corresponding Remarks
Category/ XML Schema Mandatory
S.N. Label in Web
Nodes Elements/Tags My Client Not My
Interface
Client
tax_number PAN
tax_reg_number Grandfather’s
Name
source_of_wealth Source of Income

passport_number Passport Number

passport_country Passport Country
date_deceased Date of Death
comments Comments
name Name Mandatory Mandatory
commercial_name Commercial
Name
incorporation_legal_fo Registration Mandatory
rm Legal Form
incorporation_number Registraion Mandatory
Number
business Business Mandatory
email Email
url Url
incorporation_state Registering Mandatory
5 Entity
Authority
incorporation_country_ Registration Mandatory
code Country Code
incorporation_date Registraion Date
tax_number PAN/VAT Mandatory
Number
tax_reg_number PAN/VAT Reg. Mandatory for
Date Entity having
PAN/VAT
comments Comments
business_closed Date Closed
6 Address address_type Type Mandatory Mandatory

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 Mandatory or Non-
Corresponding Remarks
Category/ XML Schema Mandatory
S.N. Label in Web
Nodes Elements/Tags My Client Not My
Interface
Client
address Address Mandatory Mandatory
town Municipality/VD
C
city District Mandatory Mandatory
zip Ward No.
country_code Country Mandatory Mandatory
state State
comments Comments
tph_contact_type Contact Type Mandatory Mandatory
tph_communication_ty Comm. Type Mandatory Mandatory
pe
7 Phones tph_country_prefix Country Prefix
tph_number Number Mandatory Mandatory
tph_extension Extension
comments Comments
type Type Mandatory Mandatory
number Number Mandatory Mandatory
issue_date Issue Date
Identificatio
8 expiry_date Expiry Date
n
issued_by Issued By Mandatory Mandatory
issue_country Issue Country Mandatory Mandatory
comments Comments
account Account Number Mandatory Mandatory
account_name Name Mandatory Mandatory
for specified
cases
9 Account institution_name Institution Name Mandatory Mandatory
branch Branch
non_bank_institution Non-Banking
Institution?
institution_code Institution Code

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 Mandatory or Non-
Corresponding Remarks
Category/ XML Schema Mandatory
S.N. Label in Web
Nodes Elements/Tags My Client Not My
Interface
Client
swift Swift One of these One of these
two is two is
mandatory mandatory
personal_account_type Account Type Optional
status_code Status Code Optional
currency_code Currency Code Optional
iban Client’s Risk Optional
Grade
client_number Client Number

opened Opened Optional

closed Closed
balance Balance Optional
date_balance Date of Balance Optional
beneficiary Beneficiary
beneficiary_comment Beneficiary
Comment
comments Comments

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4. DESCRIPTION OF 'TRANSACTION MODE MASTER' AND 'FUNDS TYPE
MASTER'

4.1 Transaction Mode Master

The values that can be provided in Transaction Mode are bound to predefined list. While the
available options can be selected from drop down list in Web, such values should be provided as
corresponding code while submitting reports in XML format. If any code other than specified in
the Lookup table is provided, the XML file will not be validated and hence the lookup value should
be chosen and provided carefully for different type of transactions. The available values for
Lookup Table ‘Transaction Mode Master’ are listed below:

Code Value/Transaction Mode Description

A In-Branch If the transaction is carried out in the same branch
where the policy was issued.
C Different Branch If the transaction is carried out in branch other than
the branch where the policy was issued.
D Electronic Transfer Any other form of Electronic/Internet Transfer other
than ECC, IPS and RTGS
Z Others If Transaction Mode is any other than listed above

4.2 Funds Type Master

Similar to the Transaction Mode, the values that can be provided in Funds Type are bound to
predefined list. While the available options can be selected from drop down list in Web, such
values should be provided as corresponding code while submitting reports in XML format. If any
code other than specified in the Lookup table is provided, the XML file will not be validated and
hence the value should be chosen and provided carefully for different type of transactions.
Although the Funds Type Lookup Table is same for both from Party and To Party, but the values
that need to be selected are different for different type of transaction which has been illustrated in
table 2.2. The available values for Lookup Table ‘Funds Type Master’ are listed below:

Code Value Description

K Cash Select for Deposit or Withdrawal of Cash

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 P Cheque Select for Deposit of Cheque
F Transfer Receive Select for Transaction like IPS, RTGS, Electronic Transfer, SWIFT
etc.
Z Others Provide if To or From Funds Type is different than listed above

Note: Complete list of lookup values can be found in goAML XML Schema which can be downloaded by
logging in goAML and going to NEW REPORT→XML Report Validator.

5. MESSAGE BOARD

 'Message Board' is communication portal within goAML. FIU-Nepal may request information
with the Co-operatives about specific person, account or entity during course of analysis of any
particular STR/SAR/TTR through message board. Information requested through goAML
Message Board should be replied at an earliest, not exceeding three working days, to same
analyst (e.g. Analyst 1, Analyst 2 etc.) or person requesting from FIU-Nepal.
 The requested information and documents should be replied in Message Board itself (not in
different email) and manual submission of hard copy documents is not required.
 After submission of report, notification regarding status of the submitted report can also be seen
in message board.

6. SUMMARY OF IMPORTANT POINTS

I. If any information is available with the REs, it should be reported in proper fields of
goAML, regardless of whether fields are MANDATORY or OPTIONAL
II. ‘Unknown’, ‘Not Available’ etc. will generally not be accepted in Personal details, Entity
details and other relevant fields for regular transactions and normal cases
III. If Non-Mandatory/Optional information is unknown, such fields may be omitted in XML
or left blank instead of providing ‘Unknown’, ‘Not Available’, ‘-’ etc. in such fields. Same
should be considered while submitting reports manually through Web
IV. No extra spaces, dashes, characters and punctuation should be included unless they are
present in the valid document while providing information in any field. Information such
as Citizenship number, Person name, Entity name should be provided exactly as per legal
documents

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 V. Abbreviations/short forms should be avoided as far as possible while providing
information like Person Name, Entity Name, Address, Registering Authority, Occupation,
Business etc. but if abbreviations/short forms are present in legal documents like
Citizenship, Registration Certificate etc., then such information should be provided exactly
as per legal documents
VI. Re‐occurring information, such as Reporting Entity names, Branch names, Location etc
must be reported consistently, i.e. with the exact same wording every time
VII. Re‐occurring information such as Personal details, ID details, Address and Contact details
for the same person in From Party, Conductor and To Party should be provided completely
and consistently for all occurrences in reported transactions
VIII. While submitting reports manually by Web, “Use an Existing …….” button on the top
right corner of the screen can be used to avoid re‐entering details of Persons/Account/Entity
that is already entered while reporting multiple transactions. This saves time and ensures
that the information is consistent throughout the report
IX. While reporting STR, the Co-operatives should provide as much suspicious and related
transactions as they can whether in XML format or manually through Web by performing
preliminary analysis at their end but regular/unsuspicious transactions needn’t be provided
in XML format.
X. If Conductor is different from the beneficiary i.e. ‘From Party – Person’ or ‘To Party –
Person’, then the information like Contact detail and Identification required for some cases
should be collected on behalf of Conductor rather than the beneficiary
XI. ‘Source of Fund’ and ‘Purpose of Transaction’ should be provided for all required cases
XII. In case of change of Compliance officer or change in any details (e.g. Mobile No.) of
existing compliance officer, new details shall be updated in goAML's user details within 3
working days of such changes happened, by following process:

Login >> ADMIN >> Active Users >> Click on '+' sign to make new changes

In addition, at least one mobile number and one landline no. with proper extension number
shall be provided in user details portion. Email id of the user should be generic (e.g.
[email protected]) rather than personal and always should be updated in goAML. FIU-

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Nepal will communicate to email id updated in goAML whenever any amendment/changes
shall be circulated.

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7. FREQUENTLY ASKED QUESTIONS

1) Do Reporting Entities (REs) need to pay fee or any charges to FIU-Nepal for membership
of goAML software?
No. Co-operatives do not need to pay any fee or charges to FIU-Nepal for goAML membership
or for reporting purpose. Membership of goAML software to all REs (BFIs, Co-operatives
companies, Securities companies, Cooperatives, Remittance companies etc.) is free of cost.

2) How should TTR be reported?

TTR can be reported either in XML format or manually through Web. XML files can be
uploaded individually or as a zip file comprising of multiple TTRs. Zip upload is recommended
for large volume of TTRs.

3) In which format should TTR be reported?

One XML file should be submitted for each TTR Category as specified in directive. i.e. One
XML file should contain TTR related to only one person or account comprising of all the
transactions in that particular day in which TTR was generated. Different XML file should be
submitted for different TTRs.

4) How should TTR be reported when members do transactions through different payment
modes like Cheque, Cash, IPS?
Multiple Transactions should be included within single report. For example, for the deposit
amount of Rs. 10,50,000, If Rs. 9,50,000 is received via cheque and Rs. 1,00,000 via cash,
then TTR should be submitted including two transactions within it:
 Cheque Deposit of 9,50,000
 Cash Received of 1,00,000

5) In case of Minor/Child account where there is Legal Guardian, whose details should be
submitted in field of To Party Related Person (Signatory) while reporting TTR?

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 In case of minor/child account, primary signatory must be 'Legal Guardian' at least mandatory
field details of legal guardian must be filled.

6) How should TTR of multiple transactions of same individual/entity (Co-operatives) be

reported?
In case of multiple transactions of same individual/entity following procedures needs to be
followed;
 UNIQUE ID of individual/entity shall be used as 'Account Number' ('To My
Client>Account>Account Number) instead of individual account number.
 Each transaction carrried out must be reported inside the single report.
 Opened date' (To My Client > Account > Opened date) shall be the date of 'First date
of First account (among all existing active account).
 Total number of existing accounts of each UNIQUE ID shall be mentioned in
'Description' (Transaction > Description).

7) How should STR be reported?

STR can be reported either in XML format or through Web reporting in goAML. If large
number of suspicious transaction has to be reported, XML format is recommended.
Information to be provided with STR is mentioned in Operational guidelines designated to
reporting entities. While reporting STR as XML file, related attachments and the XML should
be zipped together and uploaded as single zip file.

8) What information should be provided in Reason Fields of STR/SAR?

It has been specified in Operational guidelines designated to reporting entities. Refer 1.2.6.2
(C)

9) What attachments should be provided with STR/SAR?

It has been specified in Operational guidelines designated to reporting entities. Refer 1.2.6.2
(D)

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10) What information to provide in ‘Registration No.’ field for Entity that do not have
registration number e.g. Joint Venture Account.?
Provide ‘Not Applicable’ in such cases.

11) What information to provide in ‘PAN/VAT Number’ field for Entity that do not require
PAN/VAT to be registered?
Provide ‘Not Applicable’ in such cases.

12) Should Entity details be provided for My Client > Account > Entity though it is not
Mandatory?
‘My Client > Account > Entity’ is not mandatory only if the account is individual or joint
account. In case the account belongs to an Entity, Entity details should be provided along with
Director(s) and Signatory details.

13) Should Director(s) and Signatory details be provided for My Client > Entity though it is
not mandatory?
Yes, Director(s) and Signatory details should be provided for all cases where Co-operatives
need to collect such information and such information needs to be provided under Related
Person node. It is Non-Mandatory only for cases when such information isn’t required to be
collected as per existing regulations.

14) What information should be provided for Mandatory fields that are not available or not
relevant in the context?
For Text fields - Provide ‘Not Available’ for information that could be available but not
currently in the system. Provide ‘Not Applicable’ for the information that isn’t relevant to the
specific case.
For Date fields -Provide 01/01/1900
For Number fields - Provide 0

15) Should Non-Mandatory information be provided? What information should be provided

in Non-Mandatory fields?

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 Mandatory fields are meant to capture only minimum information applicable to most of the
cases. Depending upon different cases, additional information is required and it is
recommended that any information available with the Co-operatives be provided in relevant
fields whether Mandatory or Non-Mandatory.
If Non-Mandatory/Optional information is unknown, such fields may be omitted in XML or
left blank instead of providing ‘Unknown’, ‘Not Available’, ‘-’ etc. Same should be
considered while submitting reports manually through Web.

16) What information should be provided in ‘Citizenship No.’ field,’ ID number’ field,
‘Passport’ node and ‘Identification’ node for Nepalese ID?
 In case of Nepalese Citizenship – Citizenship number should be provided in
‘Citizenship No.’ field and ‘ID number’ in respective field. Other Citizenship details
should be provided in ‘Identification’ node as follows:
 In case of any other form of Identification that have Citizenship number e.g. Driving
License – Provide Citizenship number in ‘Citizenship No.’ field, Driving License
number (ID number) in ‘ID number’ field and Driving License details (ID details) in
‘Identification’ node.
 In case of Nepalese Passport – Citizenship number should be provided in ‘Citizenship
No.’ field, Passport number should be provided in ‘ID number’ field. The Passport
number and Country should also be provided in ‘Passport’ node and other Passport
details should be provided in ‘Identification’ node.
In case of any other form of Identification that do not have Citizenship number – Provide ‘Not
Applicable’ in ‘Citizenship No.’ field, corresponding ID number in ‘ID number’ field and other
available ID details in ‘Identification’ node.

17) What additional details should be provided in Identification node for Nepalese
Citizenship?
For Nepalese Citizenship, Citizenship number should be provided in ‘Citizenship No.’ and ‘ID
number’ field and Citizenship details should be provided in ‘Identification’ node. Information
that should be provided in ‘Identification’ node is Citizenship Number, Issuing Authority
(Name and Address E.g. District Administration Office, Jhapa), Issue Date and Issue Country.

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18) What information should be provided in ‘Citizenship No.’ field,’ ID number’ field,
‘Passport’ node and ‘Identification’ node for Indians and Foreigners?
 Citizenship Number is a mandatory field as per goAML schema so in case of Foreigners
and Indians having Passport– Passport number should be provided in ‘Citizenship No.’
field and ‘ID number’ field. The Passport number and Country should also be provided in
‘Passport’ node and other Passport details should be provided in ‘Identification’ node.
 In case of Indian Citizenship – Citizenship number should be provided in ‘Citizenship No.’
field and ‘ID number’ field. Other Citizenship details should be provided in ‘Identification’
node.
 In case of Indian with any other form of Identification that have Citizenship number –
Provide Citizenship number in ‘Citizenship No.’ field, ID number in ‘ID number’ field and
ID details in ‘Identification’ node.
 In case of Indian with any other form of Identification that do not have Citizenship number
– Provide ‘Not Applicable’ in Citizenship No. field and ID number in ‘ID number’ field
and other available ID details in ‘Identification’ node.
 Any other relevant Information regarding ID can be provided in Comments field of
Identification in all situations.

19) How to provide Citizenship number if it exceeds 25 characters?

If Citizenship number exceeds 25 characters (as per limit in goAML), first 25 characters should
be provided in Citizenship No. field. The complete Citizenship number should be provided in
Id Number field and other details in Identification node.

20) What information should be provided in Identification details if there’s no sufficient

information?
Mandatory information required for ID is ID Type, Number, issued by (Issuing Authority) and
Issue Country. Provide other information if available like Issue Date and Expiry Date. If
mandatory information is not present in the ID provide ’Not Applicable’ in such fields.

21) Can we register/report through multiple users for same organization?

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 No, only one user (Compliance Officer or Authorized Personnel) per Reporting Entity is
responsible for reporting in goAML. Hence, the registration email should be generic and
information update request can be sent through goAML in case of personnel change.

22) Can we use abbreviations/short forms for common terms?

Abbreviations/short forms should be avoided as far as possible while providing information
like Person Name, Entity Name, address, occupation, business etc. but if abbreviations/short
forms are present in legal documents like Citizenship, Registration Certificate etc., then such
information should be provided exactly as per legal documents.

23) How long will Drafted Reports be available for editing prior to submission?
Currently, FIU-Nepal has set it as '15 days' which can be changed as per requirement.

24) How long will be Processed/Failed Validation reports be available for preview on the
Web?
Currently, FIU-Nepal has set it as '15 days' which can be changed as per requirement.

25) What does the different status of submitted report mean and do we need to take any
action?
 In General, status is Transferred from Web, Processed, Rejected and Failed Validation.
 If there are some errors in the structure of XML file, then the status for such file can be
seen as Failed Validation and Co-operatives Companies can click on Failed Validation
link to know more about the validation errors.
 If the XML file is validated the status changes to Transferred from Web and further upon
approval from the screening officer of FIU or based on XML validation and rejection rules,
the status will be change to Processed. The Co-operatives Companies do not need to take
any actions if the status is Processed.
 In case if ‘Transferred from Web’ status is seen for longer period of time (>1 day), the Co-
operatives Companies should check their message board or email for any notification or
rejection message regarding the report.

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  If there are some logical mistakes or missing information in validated XML files, then the
screening officer (manually) or goAML rejection rules (automatically) may reject the
report with proper reason which appears as Rejected.
 REs should correct the mistakes in reports with Failed Validation, Rejected and
Transferred from Web status and resubmit those files.

26) How to validate bulk of XML files?

The ‘XML Report Validator’ in the Web Interface and an offline XML Validator Tool can be
used to validate one XML file at a time. It is not necessary to validate every XML file prior to
submission if the Co-operatives Companies have solved the common validation issues and
they are assured that no such validation errors exist in the reports. As the reports being
submitted by Co-operatives Companiess get error free with time, it is advised that the Co-
operatives Companies validate the samples from the bulk uploads. Nevertheless, there might
be some third party tools that may be available for validating bulk of XML files against the
provided XML Schema.

27) What will happen when STR/SAR/TTR is not reported?

As per ALPA, 2008, STR/SAR must be submitted as soon as possible, not exceeding three
days and TTR must be submitted within 15 days of date of transaction. Non-submission of
STR/SAR/TTR or failure to submit within prescribed time/format are subject to fine and
penalties as per ALPA, 2008 and Directives issued by Department of Co-operatives. FIU-
Nepal can impose fine up to NPR. 10 lakhs.

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For any further queries or confusions regarding goAML, please do contact the
'goAML Implementation Team' members of FIU-Nepal through:

 Email: [email protected]
 Tel: 01-5719653/54/55/56 (Ext. 418/817/828)

Please do visit our website www.nrb.org.np/departments/fiu for latest

documents, notices and information.

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Annex 1: Format of Transaction Details

Header of Transaction Details must include at least:

Name of Customer:
Address of Customer:
Date Range:
Name of Institution:

S. Name and Branch Date of Nature of Account Amount Source Remark

No address of Transa Transactio Type and Involved of s
. ction n No. Fund
the person
holding

account
(including

legal)

Note: Each column should be filled completely as far as possible.

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Annex 2: Report Status

Various status of goAML reports and its meaning:

SN Status Meaning
1 Uploaded First Status when report(web or XML) is submitted in goAML

Validated; scheduled for

2 Report is validated against the xml schema
loading

3 Failed Validation The report is not as per the XML schema.

Failed Validation; Invalid The submitted report is not as per the XML schema or the report
4
Structure not valid as per system settings.
Approved; scheduled for Report that are approved against XML schema and waiting for
5
processing system process to load into client database.
Report is validated against the xml schema but has been hit by
6 Transferred From Web Business Rule created by FIU Nepal. It will be processed or
rejected manually by FIU-Nepal Screening officer.
Report is validated against the XML Schema but has been hit by
7 Rejected
Business Rule and is rejected.

8 Processed The submitted report is process and no further action is required.

9 Reverted The rejected web reports which are reverted by RE for correction.

Only seen inside DRAFTED REPORTS->Not Submitted Web

10 Not submitted Report menu item against those report which are saved but not
submitted yet.
Only seen inside DRAFTED REPORTS->Not Submitted Web
11 Reverted - Not submitted Report menu item against those report which are reverted but not
submitted yet.

12 archived - accepted Report that are processed and are cleaned up by the security policy.

13 archived - invalid structure Report that are invalid and are cleaned up by the security policy.

Report that are not submitted and are cleaned up by the security
14 archived - not submitted
policy.
archived - reverted not
15 Report that are reverted and are cleaned up by the security policy.
submitted

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 archived - waiting to be
16 Report that are processed and are cleaned up by the security policy.
reverted

17 Unexpected Error Some system related error occurred while processing the report

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Annex 3: Commonly Made Mistakes in Reporting

STR/SAR

 Not mentioning 'Name of the Customer(s)/Account(s)" in the reason field.

 Not mentioning all stated topics in reason field as specified in Operational Guidelines
Point no. 1.2.6.2 (C) (i).
 Not providing policy details (Institution name, branch name, Policy type, account name,
account number, currency, statement period etc.) and summarized account statement
in format specified in operational guidelines.
 Not providing statement of account from date of opening (In excel format) of suspicious
Customer and other related account.
 Not providing report indicator as per updated list of indicators (Predicate Offence).
 Not providing the summary of transaction details of last five years as specified in excel
format.
 Not submitting clear and readable scanned copy of proposal form & KYM form.
 Not submitting account opening Form & KYM form in PDF format.
 Not submitting updated KYM documents in PDF format.

TTR

 Not providing the proper name for 'To Party- Person'.

 Not providing either father name or mother name for 'To Party- Person'.
 Not providing source of fund for reported cash transaction above specified threshold.
 Not providing proper 'Funds Type' (e.g. both 'To' and 'From' funds type cannot be cash).

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 NEPAL RASTRA BANK
FINANCIAL INTELLIGENCE UNIT, NEPAL
(FIU-Nepal)
Tel: 01-5719653/54/55/56 (Ext. 418/817/828)
Email: [email protected]
Website: www.nrb.org.np/departments/fiu

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