goAML filing preparation: from suspicion narrative to submit-ready package
How Belgian obliged entities should prepare STR evidence, narratives and goAML-ready files without confusing preparation with filing.
Executive summary
goAML is the operational reporting channel for Belgian STRs.Preparation should be separated from official filing.The file needs a suspicion narrative, evidence, access control and acknowledgement history.Since CTIF-CFI moved suspicious transaction reporting to goAML, the practical burden is no longer just deciding whether to report. Offices also need clean facts, a structured suspicion narrative, supporting evidence, restricted access and proof of what was submitted or why no report was made.
Sceau’s role is preparation and evidence. The office is the reporting entity; Sceau can assemble a goAML-ready package, keep the decision record and store acknowledgements after the office files through its own route.
A good STR workflow is quiet, controlled and disciplined. It avoids tipping off, separates sensitive reporting records from ordinary file notes and keeps a dated trail from first red flag to final filing or no-filing decision.
Who this applies to
This guide is for Belgian obliged entities and professional offices that need to prepare suspicious transaction reports or record why a report was not filed.
- AMLCOs and reporting officers
- Notaries, accountants, estate agents and TCSPs
- Lawyers using the appropriate privileged route
- Teams moving from paper habits to goAML-ready evidence
Legal and supervisory context
CTIF-CFI has moved suspicious transaction reporting to the goAML application. That creates a practical need for structured data, consistent narratives and evidence packages that can be uploaded or submitted through the correct official route.
A vendor can help prepare the package, but the reporting entity remains responsible for the legal conclusion, filing decision and official submission route.
What the office must actually do
The office should convert the legal requirement into a repeatable workflow with named owners, dated records and a clear review route.
- Record the first unusual fact and date.
- Escalate internally without tipping off.
- Collect supporting documents and screening evidence.
- Draft a concise suspicion narrative.
- Prepare goAML XML or web-form data.
- Record filing acknowledgement or no-report rationale.
What good evidence looks like
The evidence trail should show the red flag, escalation, analysis, decision-maker, filing package, submission proof and any CTIF-CFI follow-up.
Common mistakes supervisors find
- Waiting for proof instead of acting on suspicion.
- Discussing possible reporting with the client.
- Keeping the suspicion narrative in ordinary file notes.
- Preparing goAML data without sign-off.
- Not recording acknowledgement after filing.
Practical checklist
- Create restricted STR workspace.
- Record red flags.
- Draft narrative.
- Attach evidence.
- Approve report or no-report decision.
- Prepare goAML package.
- Record submission proof and follow-up.
- Builds STR drafts from file evidence.
- Keeps reporting records access-controlled.
- Prepares goAML-ready exports where configured.
- Records no-report decisions as evidence.
- Stores acknowledgement and follow-up history.
FAQ
Does Sceau submit directly to CTIF-CFI?
The baseline is prepare-and-evidence. Direct B2B submission requires the office’s authorised configuration and remains under the office’s responsibility.
What is a good suspicion narrative?
Short, factual and structured: who, what, when, why it is unusual, what evidence supports it and what funds or assets are involved.
Should the client know?
No. The workflow must avoid tipping off and restrict reporting records to authorised people.
Official references
From knowledge to compliance
Reading is a start. Sceau turns these obligations into a workflow that runs itself and proves itself.
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