Confirmed match, partial match or false positive: handling sanctions screening results in the UAE

• Confirmed name match: the person or entity matches all the key identifiers published on the list, for example name, nationality and date of birth all match.
• Partial name match: some key identifiers match but you cannot conclude either way, for example the name and date of birth match but the nationality differs and the spelling is slightly different.
• False positive: a hit that, on examining the key identifiers, is clearly not the designated person, for example the listed person is 40 and your customer is a 16 year old student.
• Negative match: screening found no match at all.

The EOCN guidance says screening should be done on key identifiers first, before considering others such as aliases. If none of the key identifiers match, the result is a negative match.

• Individuals: name, date of birth, nationality, ID or passport number, last known address.
• Companies: name, trade licence number, registered address, branch addresses.

In practice, most unnecessary partial matches come from missing data. If you hold a customer's date of birth, nationality and passport number from onboarding, a common name rarely stays unresolved for long.

• Existing customer: freeze without delay (within 24 hours), stop providing any funds, assets or services, and file a Confirmed Name Match Report (CNMR) in goAML within five business days of freezing.
• Potential customer or counterparty: reject the transaction or relationship immediately, do not deal with them, and file a CNMR within five business days of rejecting it, describing what was rejected and any assets frozen in the process.

A CNMR must include the match's full name and ID documents, the value of any funds or assets frozen with supporting documents such as statements or title deeds, or a description of the rejected transaction or service. The guidance assumes you hold ID documents in a confirmed match, because confirming a match without them is unlikely.

Also look back: CNMRs cover past relationships, transactions and closed accounts from the five years before the designation, even if you hold no assets today.

With an existing customer you are expected to already hold their ID documents. If, after reviewing them, you still cannot tell whether it is a confirmed match or a false positive:

• suspend any transaction without delay and stop providing funds, assets or services;
• file a Partial Name Match Report (PNMR) in goAML within five business days of the suspension, with all relevant documents; and
• keep the suspension in place until the EOCN tells you, through goAML, whether it is a false positive or a confirmed match.

Example: an existing customer's first and middle names and nationality match a newly designated person, but the listed date of birth is "approximately" one year later than the customer's. The difference is too small to rule it out, so the business suspends, files a PNMR with the customer's ID attached, and waits. If the EOCN confirms the match, the business freezes and files a CNMR. If the EOCN confirms a false positive, the business lifts the suspension and keeps a record, with no further report.

With a potential customer or a counterparty you may not hold ID documents yet. In that case:

1. make the necessary efforts to obtain their ID documents first;
2. if the documents show a false positive, you may proceed, keeping internal documentation, with no PNMR;
3. if you cannot obtain the documents within a reasonable time, which the guidance sets at 10 business days, reject the transaction or service and file a PNMR within five business days of rejecting it, stating it was rejected for lack of ID; and
4. if the documents arrive after that, screen again using them and treat it as a new transaction, filing a new report if the result requires one.

Note that the EOCN cannot verify a partial match without ID documents, so a PNMR without them cannot be resolved.

If examining the key identifiers shows the hit is not the designated person, no report is needed and the business can continue normally. You must still keep internal documentation of how you reached that conclusion. Screening records, including false positives, must be kept for at least five years, and a supervisor reviewing your file will look for exactly that reasoning.

• Releasing a suspension yourself. After a PNMR, only the EOCN's response ends the suspension.
• Treating a partial match as a false positive to avoid friction, without evidence from key identifiers.
• Not documenting false positives, leaving no audit trail of the review.
• Screening only the customer, not beneficial owners, parties to the transaction, directors and attorneys.
• Forgetting the look back to former customers and closed accounts from the last five years.
• Telling the customer why a transaction is on hold, which can amount to tipping off.

RiskLens360 gives every screening hit a match score, routes it through case management and escalation, and records who decided what and when, so false positives are documented by default and confirmed or partial matches are ready to report. Request a demo or read the full guide to screening against the UAE Local Terrorist List.