What is a Partial Name Match Report (PNMR) and when should it be filed?
A Partial Name Match Report (PNMR) is filed when a reporting entity’s screening flags a customer, related party, or beneficial owner as a possible but not confirmed match against a name on the UN Consolidated List or the UAE Local Terrorist List. Because the match is not yet confirmed, the entity cannot simply proceed, nor can it treat the alert as a full designation. It must investigate using reasonable open-source, media, and commercial-database information to determine whether the match is genuine.
While the review is ongoing, the entity should suspend transactions with the subject and refrain from providing services. If the review confirms the match, the entity freezes the funds and files a Fund Freeze Report; if it is ruled out as a false positive, the entity documents its reasoning and may proceed. The Executive Office operates a mechanism to resolve cases of names that are similar to designated persons.
Legal Reference (UAE):
· Cabinet Resolution No. 74 of 2020, Article 21(2) and (5) - requires continuous screening and immediate reporting of potential matches and similar-name cases to the supervisory authority and Executive Office.
· Cabinet Resolution No. 74 of 2020, Article 18 - sets out the mechanism for resolving cases of names similar to those designated on the Sanctions List.
For more details, consult the full text of Cabinet Resolution No. 74 of 2020 or seek guidance from your AML compliance officer.