Before you go live

In short

SpeculaPro builds goAML reports from settings: your reporting entity ID, report codes, indicator list, lookup codes and CTR rules. It starts with defaults taken from the generic goAML tables and from figures commonly cited for Ghana. None of them has been confirmed by the FIC for your institution. FIUs customise goAML, and the FIC gives each reporting institution its own values.

Work through this checklist with your MLRO and the FIC before the first real report leaves SpeculaPro. Most items are set under Settings → Reporting; see Reporting settings.

SpeculaPro checks the structure, not the FIC’s rules

SpeculaPro validates each report against the published structure of the goAML 4.0 report schema: required elements, choices, lengths, country and currency codes and dates, and it re-reads the finished file to prove it is well-formed XML. It does not validate against the FIC’s own XSD, because that file isn’t public: each FIU distributes it to its reporting entities. A report SpeculaPro accepts can still be rejected by goAML. Test a sample first (step 1).

The checklist

1. Validate a sample file. Draft a test STR from a closed test case, have it approved, export it and upload it to goAML Web’s XML validation, or validate it against the XSD the FIC gave you. Fix any setting it complains about and repeat until it passes. Don’t record the test as submitted unless it really was filed.

2. Confirm your reporting entity ID (rentity_id), your institution code or SWIFT/BIC, and, if the FIC uses them, your branch code. Every account of yours in a report carries the institution code, so reports that include your accounts fail validation without it. Until the ID is set, no report can be sent for approval, approved or exported.

3. Confirm the report codes. SpeculaPro sends STR for suspicious transaction reports and CTR for cash transaction reports. Use the codes the FIC’s goAML expects.

4. Load the FIC’s report indicator list. Enter each indicator’s code and description, then map your rules’ typologies and categories to indicator codes so new STRs start with the right ones. By default an STR needs at least one indicator before it can go for approval.

5. Confirm the lookup codes under Lookup codes (goAML XML):

   Setting	SpeculaPro’s default	Confirm
   Funds code for cash	K	The FIC’s funds type code for cash
   Funds code for account or wallet money	A	The FIC’s code for funds from an account
   Conduction type (transmode) per channel	branch, cash and agent A; ATM B; anything else C	The FIC’s transmode codes for each of your channels, especially mobile money
   ID types	Ghana Card B, passport C, driver’s licence A; voter ID, TIN, company registration and other O	The FIC’s identifier type codes, including the code for the Ghana Card
   Account status	active A, frozen B, dormant C, closed D	The FIC’s account status codes
   Contact type for customers’ phones and addresses	P (private)	The FIC’s contact type codes
   Communication type for mobile numbers	M	The FIC’s communication type codes
   Account holder role	A	The FIC’s code for the account holder on their own account

6. Confirm the schema version. SpeculaPro writes the goAML 4.0 report schema. If the FIC’s goAML only accepts schema 5.x files, don’t file from SpeculaPro: it doesn’t write 5.x yet, and the layout differs.

7. Confirm how and when to submit: the filing deadline for STRs and CTRs, whether XML upload (submission code E) is expected, and the attachments the FIC wants with an STR. The goAML file doesn’t include attachments; send them as the FIC instructs.

8. Confirm the CTR rules before switching CTRs on:

   • the threshold for individuals and for businesses. SpeculaPro’s default, GHS 50,000 per business day for both, is a commonly cited figure and must be confirmed with the FIC;
   • whether cash equal to the threshold is reported, or only cash above it (Report when the day’s cash is);
   • whether a customer’s cash transactions over the day are added together (SpeculaPro’s default in Ghana) or only single transactions that reach the threshold count;
   • which of your channels and transaction types count as cash. See Cash transaction reports.

9. Confirm the retention period for reports and their files, and record it in your AML policy. SpeculaPro never deletes a report; your backups must keep them for at least as long. See Backups if you self-host.

10. Check what the FIC expects about each person. SpeculaPro reports what it holds: names, date of birth or registration, nationality, ID type and number, phone (split into goAML’s country prefix, tph_country_prefix, and the national number; a number whose country can’t be told is sent whole), email and occupation. It doesn’t hold customers’ postal addresses, so none are reported. If the FIC requires addresses, add them in goAML Web or in the narrative, and tell [email protected].

11. Name the reporting person and location. Enter the compliance officer named on every report and the office address. goAML may refuse reports without them.

12. Agree who drafts, who approves and who files. Approval needs a second person: make sure you have one. See Who can do what.

Keep the evidence of your checks

File the FIC’s confirmation of each value, and the result of the sample upload, with your AML programme documents. Examiners may ask how you know your reports reach the FIC correctly.

If you report to a CENTIF

In the UEMOA states and Guinea the checklist above still applies where it isn’t about goAML: the report codes (DOS, DTE, or DSTE in Côte d’Ivoire), the indicator list, the CTR rules, the reporting person and location, and who drafts, approves and files. The lookup codes and the goAML schema version don’t apply. Add these checks:

1. Ask your CENTIF how it takes declarations: through a portal (e-Delta in Senegal, Mon Espace CENTIF in Côte d’Ivoire), on its own forms, on paper, or as files.
2. Show it a sample. Export a test declaration and ask whether the CENTIF accepts SpeculaPro’s printed form. Its layout and XML schema are SpeculaPro’s own and no CENTIF has confirmed them. If the CENTIF requires its own form or portal, file there and keep SpeculaPro’s declaration as your record.
3. Confirm the CENTIF’s postal address and the legal basis printed on the form. The jurisdiction gives only the city and a general wording of the law.
4. Make sure customers’ identity documents reach SpeculaPro. A cash declaration (DTE) can’t be approved or exported for a customer with no identity document on file.
5. Enter the institution’s street address and the compliance officer’s phone or email under Settings → Reporting: the declaration needs them.

This is not legal advice: confirm your filing duties with counsel and your CENTIF. See Filing with a CENTIF.

Related

• Reporting settings
• Filing with goAML
• Filing with a CENTIF
• Cash transaction reports
• Regulatory reporting