What is the difference between a confirmed match and a potential match in sanctions screening?
In UAE sanctions screening, a confirmed match and a potential match trigger different actions. A confirmed match means the reporting entity has established that a customer, related party, or beneficial owner is in fact the person or entity designated on the UN Consolidated List or the UAE Local Terrorist List. Once confirmed, the entity must freeze all relevant funds without delay and without prior notice, then file a Fund Freeze Report with the Executive Office within five working days.
A potential match, sometimes called a partial name match, means the screening tool has flagged a similarity but identity has not been confirmed. In that situation the entity must not proceed as normal; it should suspend the transaction, investigate using reliable information to confirm or rule out the match, and file a Partial Name Match Report. If the match is confirmed it escalates to a freeze and an FFR; if it is a false positive the entity documents the decision and may continue the relationship.
Legal Reference (UAE):
· Cabinet Resolution No. 74 of 2020, Article 21(2) and (3) - requires ongoing screening and freezing without delay as soon as any match appears.
· Cabinet Resolution No. 74 of 2020, Article 15(2) - requires notification to the Executive Office within five working days of the freeze.
For more details, consult the full text of Cabinet Resolution No. 74 of 2020 or seek guidance from your AML compliance officer.