What must a UAE reporting entity do when it finds a confirmed sanctions name match?
On a confirmed match to a designated person or entity, act immediately. Cabinet Resolution No. 74 of 2020 Article 15 requires you to freeze all funds owned or controlled, directly or indirectly, by the designated party, without delay and without prior notice, which under Article 1 means within 24 hours of the listing. You must not tip off the customer or process the transaction.
Next, notify the Executive Office of the freezing measures taken within five working days, and file the confirmed match report through goAML. Providing any funds or services to the designated party is prohibited unless the Executive Office grants a licence. Keep full records of the screening result, the decision, and the freeze so the action can be evidenced during supervision. If the match is only partial, do not freeze; suspend the transaction and file a partial name match report instead so the Executive Office can investigate.
Legal Reference (UAE):
· Cabinet Resolution No. 74 of 2020, Article 1: 24-hour freezing standard.
· Cabinet Resolution No. 74 of 2020, Article 15: freeze, notify within five working days, report.
For more details, consult the full text of Cabinet Resolution No. 74 of 2020 or seek guidance from your AML compliance officer.
A PNMR (Partial Name Match Report) is filed when sanctions screening returns a partial match to a listed name that you cannot immediately dismiss as a false positive. A CNMR (Confirmed Name Match Report) is filed when you have established a true match to a designated person or entity. Both are submitted through goAML, but they carry very different consequences.
On a confirmed match you must freeze funds without delay and without prior notice under Cabinet Resolution No. 74 of 2020 Article 15, then notify the Executive Office within five working days and file the report. On a partial match you should suspend the transaction and submit the PNMR so the Executive Office can investigate, rather than freezing or proceeding on your own judgement. Article 18 of the same resolution sets out how a person whose name is merely similar to a designated party can seek de-freezing. Distinguishing the two correctly protects both compliance and bona fide customers.
Legal Reference (UAE):
· Cabinet Resolution No. 74 of 2020, Article 15: freezing on a confirmed match.
· Cabinet Resolution No. 74 of 2020, Article 18: de-freezing mechanism for similar names.
For more details, consult the full text of Cabinet Resolution No. 74 of 2020 or seek guidance from your AML compliance officer.