AML in UAE: A Guide to Filing Funds Freeze Report & Partial Name Match Report

As per the UAE’s Anti-Money Laundering and Combatting Financing of Terrorism (AML-CFT) laws, relevant entities are required to meet two new requirements. The relevant entities must file two reports in the goAML system:  Funds Freeze Report (FFR) and Partial Name Match Report (PNMR). The relevant entities are Financial Institutions ( FI) and Designated Non-Finance Businesses and Professions (DNFBPs). AML consultants in Dubai can provide more insights on registering the two reports on the goAML system.

The new obligations are related to the requirements as per the Targeted Financial Sanctions (TFS). It is the duty of the AML compliance officer appointed by the rotting entities to ensure the companies abide by the reporting requirements. Failure to comply with the TFS requirements may attract severe consequences. Read ahead to understand how to raise the FFR and PNMR to ensure AML compliance in the UAE.

Legislation Governing the Requirement 

The obligation for TFS in the UAE is enshrined in Cabinet Decision (74) of 2020 Regarding Terrorism Lists Regulation and Implementation of UN Security Council Resolutions on the Suppression and Combating of Terrorism, Terrorist Financing, Countering the Proliferation of Weapons of Mass Destruction and its Financing and Relevant Resolutions. Consult with AML consultants in Dubai to meet the requirements as per the TFS. Now, let us move ahead to know further about FFR and PNMR.

Funds Freeze Report 

A Funds Freeze Report is used to report any freezing measure, prohibition on providing funds or services, and any attempted transactions linked to confirmed matches. AML advisers in Dubai can help the entities with FFR filing.

Partial Name Match Report  

A Partial Name Match Report (PNMR)  must be used to report any potential match. AML consultants in Dubai can help the entities with PNMR reporting.

Procedures on TFS reporting via the goAML Platform

The following procedures must be implemented in two different scenarios:

1. Procedures When a Confirmed Match is Identified

Entities under AML obligation may identify a confirmed match against a list of names of individuals, groups or entities to the UAE Local Terrorist List or UNSC Consolidated List is. If a confirmed match is identified, the entities must initiate the following actions:

  1. Implement all the required freezing measures immediately as set out in the Cabinet Resolution No. (74) of 2020 and the Guidance on TFS released by the Executive Office
  2. The entities must report to the Executive Office actions such as freezing measures, prohibition to provide funds or services, and any attempted transactions. These actions must be reported to the Executive Office through the goAML platform within two business days by selecting the FFR
  3. Upload all the necessary information and documents related to the confirmed match on the goAML platform along with the FFR
  4. Entities must uphold freezing measures they have taken against the confirmed match until they receive further instructions are received from Executive Office
  5. The entities must notify and share a copy of the report with their respective Supervisory Authority

2. Procedures When a Potential Match is Identified

Entities under UAE AML obligations must take the following actions when they identify a potential match to a listing of names of individuals, groups, or entities to the UAE Local Terrorist List or UNSC Consolidated List:

  1. Immediately suspend all transactions and keep away from offering funds or services, as specified in the Cabinet Resolution No. (74) of 2020 and Guidance on TFS issued by the Executive Office
  2. Report the potential match to the Executive Office and the IEC and the Central Bank of the UAE through the goAML platform by selecting the Partial Name Match Report (PNMR)
  3. Make sure to upload all the necessary information and documents in connection to the name match
  4. Entities must hold suspension measures they have taken in connection with the potential match until the Executive Office issues further instruction on whether to cancel the suspension measures or to implement freezing measures. The instructions will be issued through the goAML platform
  5. Notify and share a copy of the report with the entity’s Supervisory Authority and Financial Crime Prevention Unit

How can Jitendra Chartered Accountants Help You? 

Entities that fail to raise relevant TFS reports will be considered as violating Cabinet Resolution No. (74) of 2020. Raising the FFR and PNMR reports on the goAML platform is a complex process requiring meticulous execution. Most reporting entities lack sufficient knowledge and resources to execute the reporting requirements. This is where the best AML consultants in Dubai such as Jitendra Chartered Accountants (JCA) come in handy for the companies under obligation. JCA has a team of qualified professionals who are well-versed in AML-CFT laws and regulations. JCA can advise the organisations on how to comply with TFS requirements and help with sanction screening. Consult with JCA today to ensure AML and TFS compliance in the UAE.