CNMR and PNMR in goAML: how to report sanctions matches in the UAE

If your procedures still mention a Funds Freeze Report (FFR), they are out of date. In its July 2025 update the EOCN renamed the FFR to the Confirmed Name Match Report (CNMR), and it expanded the procedure for Partial Name Match Reports. The March 2026 amendment kept these names and updated the legal references to Federal Decree Law No. 10 of 2025 and Cabinet Resolution No. 134 of 2025. Update internal manuals, training and screening system labels to match.

• Confirmed match, existing customer: freeze without delay (within 24 hours), stop all services, then file a CNMR.
• Confirmed match, potential customer or counterparty: reject the transaction or relationship, do not deal with them, then file a CNMR.
• Partial match, existing customer (you hold their ID and still cannot decide): suspend without delay, stop services, then file a PNMR.
• Partial match, potential customer or counterparty: try to obtain ID documents first. If you cannot within 10 business days, reject and file a PNMR.
• False positive: no report. Keep internal documentation of why it is not the designated person.

Deciding between these results is explained in confirmed match, partial match or false positive.

Both reports are due within five business days, counted from the action you took, not from the screening itself:

• from freezing, for a CNMR on an existing customer;
• from rejecting the transaction or service, for a CNMR on a prospect or counterparty;
• from suspending, for a PNMR on an existing customer; and
• from rejecting, for a PNMR on a prospect or counterparty after the 10 business day ID window.

The freeze or suspension itself cannot wait for the report. It must happen without delay, and a freeze within 24 hours of the designation.

• The full name of the confirmed match, with ID documents: passport or ID card for an individual, trade licence and articles of association for a company. The EOCN assumes you hold these, because a match cannot realistically be confirmed without them.
• The value of funds or other assets frozen, with proof such as account statements, transaction receipts, portfolio summaries, title deeds or insurance policies.
• A description of the rejected transaction or service where nothing is held, for example a refused property sale or jewellery purchase.

Example: a real estate broker screening the parties to a sale finds the prospective seller is a confirmed match. The broker blocks the transaction, stops all services, and files a CNMR describing the property's type, value and location with the title deed and the seller's ID attached.

• the full name of the partial match, with ID documents if and when available;
• the value of any funds or assets suspended, with proof; and
• a description of any rejected transaction or service.

Attach ID documents whenever you can: the EOCN cannot verify a partial match without them. After an existing customer PNMR, keep the suspension in place until the EOCN responds through goAML:

• if it is a confirmed match, freeze the assets and file a CNMR; or
• if it is a false positive, lift the suspension and document it, with no further report.

If a rejected prospect sends ID documents after the 10 business days, screen again using them and treat it as a new transaction.

A designation can relate to someone you dealt with before. Reports also cover previous business relationships, transactions and closed accounts from the five years before the designation, even if you hold no funds today. In that case, say clearly in the report that nothing is currently held, that there is no current relationship, and whether the accounts are closed.

Financial institutions, DNFBPs and virtual asset service providers report through goAML. Persons who do not fall into those categories, and so have no obligation to register on goAML, report measures to the EOCN by email at tfs@eocn.gov.ae, also within five business days.

They are easy to confuse because all three go through goAML, but they serve different purposes:

• CNMR and PNMR report targeted financial sanctions measures on a match against the UAE Local Terrorist List or the UN Consolidated List, and go to the EOCN and your supervisory authority.
• A suspicious transaction report (STR) is filed with the Financial Intelligence Unit when you suspect, or have reasonable grounds to suspect, that a transaction or funds are linked to a crime, regardless of value, under Article 18 of Federal Decree Law No. 10 of 2025.

In both cases, keep it confidential. Warning a person or disclosing that a transaction is under review as suspicious is an offence under Article 29 of the same law.

Keep records of every screening result for at least five years, including confirmed matches, partial matches and false positives. RiskLens360 records each hit, decision and escalation in case management with full audit logs, and supports SAR, ISTR and goAML reporting, so the file behind a CNMR or PNMR is already in one place. Request a demo.