Sanctions and PEP screening for the UAE: the Local Terrorist List, the 24-hour freeze and the five-day CNMR.
Screen customers, beneficial owners and counterparties against commercial provider lists and lists you upload yourself, such as the UAE Local Terrorist List, with fuzzy matching built for names written in more than one script. Each list is versioned and each cleared look-alike goes through a structured, reviewable workflow, so every match decision can be traced to the list version behind it.
The UAE's rules in brief.
- Sanctions law
- Article 19(1)(e) of Federal Decree by Law No. 10 of 2025: implement the targeted financial sanctions instructions of the Executive Office for Control and Non-Proliferation (EOCN) forthwith; Cabinet Decision No. 74 of 2020 sets the detailed TFS duties
- Lists to screen
- The UAE Local Terrorist List and the UN Security Council Consolidated List, with updates received through the EOCN's Notification Alert System
- When to screen
- Immediately on every list update, before onboarding, at periodic KYC reviews or a material change in the customer, and before processing any counterparty's transaction
- Freeze
- Without delay, meaning within 24 hours, and without prior notice to the listed person
- Confirmed match
- A Confirmed Name Match Report (CNMR, formerly the Funds Freeze Report) through goAML to the EOCN and your supervisor within five business days of freezing, or of rejecting a prospective customer
- Partial match
- Suspend a match that cannot be verified and file a Partial Name Match Report (PNMR) within five business days; if identification is not obtained within 10 business days, reject the business
- Owned or controlled entities
- Frozen too where a designated person holds more than 50% of the proprietary rights or a controlling interest
- PEPs
- Cabinet Resolution No. 134 of 2025, Article 16: senior-management approval, source of funds and wealth, and enhanced ongoing monitoring for every foreign PEP; the same for domestic and international-organisation PEPs in a high-risk relationship
- Exchange houses
- Real-time screening of every party before a transaction executes, including the remitter, the beneficiary and the beneficiary bank on a money transfer (CBUAE Standards for exchange business, Chapter 16)
Checked against primary sources on 1 October 2026.
What the UAE requires, and how the module handles it
The UAE's screening duties sit in Article 19 of the 2025 Decree by Law, Cabinet Decision No. 74 of 2020, the EOCN's targeted financial sanctions guidance and Article 16 of Cabinet Resolution No. 134 of 2025, with sector rules from the CBUAE and from VARA in Dubai. Below, each duty is paired with its source and with what the screening module does about it.
| What the UAE requires | Where it sits | How the module handles it |
|---|---|---|
| Register for the EOCN's list alerts, then screen customers, beneficial owners and counterparties on every list update, before onboarding and at periodic reviews | Cabinet Decision No. 74 of 2020, Art. 21; EOCN TFS web page | Lists arrive by sync from commercial providers, and a list you keep yourself, such as the UAE Local Terrorist List, can be uploaded by hand to sit beside them. |
| Freeze within 24 hours of a confirmed match, with no notice to the listed person, and report it by CNMR within five business days | Decree by Law No. 10 of 2025, Art. 19(1)(e); EOCN TFS guidance (July 2025), para 43 | Every list is versioned, and freshness and coverage dashboards show the screening used current data, not a stale copy. Each match decision lands in an append-only audit log; the freeze itself is applied in your core banking, exchange or wallet system. |
| Exchange houses: screen all parties to a transaction, including the remitter, the beneficiary and the beneficiary bank, before it is executed | CBUAE Standards for exchange business, 16.25.1 and 16.25.8(b) | Fuzzy, multi-script and locale-aware matching compares a name across scripts and spellings, and the match-scoring engine lists the three strongest reasons for each hit. |
| Suspend on a partial match, work it to a decision, file a PNMR where it cannot be cleared, and tell the supervisor about false positives you cannot dismiss | EOCN TFS guidance and web page; Cabinet Decision No. 74 of 2020, Art. 21 | A structured workflow for clearing look-alike names keeps dispositions consistent and open to review, and they need not be redone whenever a list changes. The suspension itself is applied in your core system. |
| Identify PEPs; for foreign PEPs, and for domestic or international-organisation PEPs in a high-risk relationship, get senior-management approval, establish source of funds and wealth, and monitor more closely | Cabinet Resolution No. 134 of 2025, Art. 16 | When a customer matches a PEP record, the match counts in their risk rating and starts an EDD review in case management; follow-up reviews then run on the schedule set for their risk band. |
| Freeze entities a designated person owns more than 50% of or controls, and identify every beneficial owner holding 25% or more | EOCN TFS guidance; Cabinet Resolution No. 134 of 2025, Art. 10(1) | Entity resolution and a beneficial-owner graph in the case workbench take screening past a company's name to the people who own or control it. |
Summaries of the primary texts as checked on 29 September and 1 October 2026: Federal Decree by Law No. 10 of 2025, Cabinet Resolution No. 134 of 2025, Cabinet Decision No. 74 of 2020, the EOCN's TFS guidance (last amended July 2025) and web page, MoET's March 2026 STR/SAR guidance and Circular No. 3 of 2025, Cabinet Resolution No. 71 of 2024, the CBUAE's Standards for exchange business and VARA's Compliance and Risk Management Rulebook. Not legal advice.
Frequently asked questions.
Which sanctions lists must UAE institutions screen against?
The UAE Local Terrorist List and the UN Security Council Consolidated List. The EOCN asks reporting entities to register on its Notification Alert System for updates, and to screen immediately on every update, before onboarding, at periodic reviews and before processing a counterparty's transaction. MoET's Circular No. 3 of 2025 to accounting firms and corporate service providers adds that screening does not depend on a transaction's value or payment method.
What is a CNMR and when is it due?
A Confirmed Name Match Report, previously called the Funds Freeze Report (FFR). When an existing customer is confirmed as a match with the UAE Local Terrorist List or the UN Consolidated List, the funds are frozen without delay, within 24 hours, and the CNMR goes through goAML to the EOCN and your supervisor within five business days of the freeze. For a prospective customer or counterparty, the transaction is rejected and the CNMR is due within five business days of the rejection. That is the EOCN's guidance, last amended July 2025, and MoET's March 2026 guidance repeats it.
What should happen after a partial name match?
Where a partial match cannot be verified, suspend or reject the transaction, provide no funds or services, and submit a Partial Name Match Report (PNMR) through goAML to the EOCN and your supervisor within five business days of the suspension or rejection. While you work on the match, the EOCN allows a reasonable time, which it puts at 10 business days, to obtain identification documents; if they do not arrive, the transaction or service is rejected and the PNMR follows within five business days of the rejection.
What does UAE law require for politically exposed persons?
Article 16 of Cabinet Resolution No. 134 of 2025 separates foreign PEPs from domestic PEPs and people with a prominent function in an international organisation. Every foreign PEP needs senior-management approval to start or continue the relationship, reasonable measures to establish the source of funds and wealth, and enhanced ongoing monitoring; the other two groups get the same measures where the relationship is high risk. Sector rules go further: the CBUAE's Standards require enhanced due diligence on every PEP served by an exchange house, approved by the compliance officer and the manager in charge before any transaction, and VARA requires MLRO and senior-management approval before a Dubai VASP takes on a PEP.
What are the penalties for failing to screen or freeze?
Breaching the EOCN's targeted financial sanctions instructions is a crime under Article 33 of the 2025 Decree by Law, punishable by imprisonment and a fine of at least AED 20,000, or either. For DNFBPs supervised by MoET or the Ministry of Justice, Cabinet Resolution No. 71 of 2024 adds administrative fines, for example AED 50,000 to AED 1,000,000 for not screening databases and transactions, and AED 500,000 to AED 1,000,000 for not freezing promptly.
Does the software freeze accounts?
No. Funds are frozen in your core banking, exchange or wallet system. What the screening module supplies is the evidence: the scored match, the list version it was found against and the analyst's disposition, all kept in an append-only audit log.
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