What is a Fund Freeze Report (FFR) and when must it be filed?
A Fund Freeze Report (FFR) is the report a UAE reporting entity submits to record that it has applied targeted financial sanctions and frozen the funds of a designated person or entity. It is filed after a confirmed match is found between a customer, related party, or beneficial owner and a name on the UN Consolidated List or the UAE Local Terrorist List. The FFR captures the identity of the subject, the funds or assets frozen, and the actions taken.
The underlying freeze must happen first, without delay and without prior notice to the customer. The entity must then notify the Executive Office of the freezing measures taken within five working days from the date of the freeze. Registration on the Executive Office notification system and effective ongoing screening are what allow an entity to detect the match that triggers an FFR in the first place.
Legal Reference (UAE):
· Cabinet Resolution No. 74 of 2020, Article 15(1) and (2) - requires freezing without delay and notification to the Executive Office within five working days of the freeze.
· Cabinet Resolution No. 74 of 2020, Article 21(3) and (5) - obliges reporting entities to freeze on any match and to report the match and actions taken.
For more details, consult the full text of Cabinet Resolution No. 74 of 2020 or seek guidance from your AML compliance officer.