Local Terrorist List
In a Nutshell
- The UAE Local Terrorist List is the national terrorist designation list issued by the UAE Cabinet under UNSCR 1373 (2001); all regulated entities must screen against it alongside the UN Consolidated List.
- Confirmed name matches require a CNMR filed through goAML within five business days; partial or unresolved matches require a PNMR filed within five business days of the applicable trigger.
- Freezing must occur without delay, defined in Article 1 of Cabinet Decision No. 74 of 2020 as immediately or within 24 hours of the designation.
- PNMR and CNMR are the applicable report types. PNMR is used for unresolvable partial matches, whereas CNMR is used for confirmed matches.
- Vendor screening lists are not a substitute for EOCN list access; registration on the EOCN Notification Alert System is mandatory for timely re-screening on list updates.
The UAE Local Terrorist List is the domestic terrorist designation instrument that sits alongside the UN Consolidated List within the UAE Targeted Financial Sanctions framework. All regulated entities, including financial institutions, DNFBPs, and VASPs, are required to screen against both lists, freeze confirmed matches without delay, and file the appropriate goAML report within defined timelines.
Applicable goAML Report Types: PNMR and CNMR
The two goAML report types applicable to UAE Local Terrorist List screening outcomes are:
The Confirmed Name Match Report (CNMR) is filed when a match with the UAE Local Terrorist List is confirmed after reviewing identity documents and supporting materials. The confirmed match must be frozen without delay, and the CNMR must be submitted through goAML within five business days with all supporting documentation.
The Partial Name Match Report (PNMR) is filed when a potential match with the Local Terrorist List cannot be conclusively confirmed or dismissed after initial screening. The appropriate response depends on the scenario: for an existing customer, transactions are suspended while the match is investigated; for a prospective customer, the relationship is rejected if identity verification cannot confirm or dismiss the match within ten business days; for a transaction in progress, the transaction is suspended during investigation. In each scenario, a PNMR must be submitted through goAML within five business days of the applicable trigger event.
These report types are not interchangeable with the STR or SAR. A Local Terrorist List match requires CNMR or PNMR, depending on the outcome. If the match involves third-country sanctions lists outside the UAE TFS framework (such as OFAC or EU sanctions), or if suspicious activity exists independently of the sanctions match, an STR or SAR should also be considered in consultation with the supervisory authority.
The Freeze Obligation: Timing and Mechanics
Cabinet Decision No. 74 of 2020 defines “without delay” for the purposes of the TFS freeze obligation as immediately, or in any case within 24 hours of the listing decision being issued. This is not a business-day calculation.
Freezing means preserving all funds and assets owned or controlled, directly or indirectly, by the designated person and prohibiting the provision of funds or services. The frozen account must be maintained, not closed. An institution that closes a designated customer’s account rather than freezing it is itself in breach of Cabinet Decision No. 74 of 2020, because closing an account enables the account holder to access or move the balance.
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When to Screen Against the UAE Local Terrorist List
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| Screening Trigger | Applicable Report Type if Match Identified |
|---|---|
| At onboarding: all prospective customers, beneficial owners, directors, and authorised signatories | CNMR if confirmed match; PNMR if partial/unresolvable match within 10 business days |
| Before executing transactions: originators, beneficiaries, and intermediaries | CNMR if confirmed match; PNMR and suspend transaction if partial match |
| On each EOCN list update: immediate re-screening of the full customer base | CNMR or PNMR, as applicable; freeze within 24 hours of designation |
| At periodic KYC review or on material profile change | CNMR or PNMR, as applicable; document the re-screening outcome regardless |
EOCN Registration and goAML Registration: Two Separate Requirements
Regulated entities must maintain two distinct registrations for Local Terrorist List compliance. The first is registration on the EOCN Notification Alert System (NAS), which is operated by the Executive Office for Control and Non-Proliferation and delivers automated email notifications of listing, re-listing, update, and de-listing decisions. This registration is required under Article 21 of Cabinet Decision No. 74 of 2020 and is separate from any third-party screening vendor subscription.
The second is registration on the goAML platform, which is the mechanism through which all CNMR, PNMR, STR, and SAR reports are filed with the UAE FIU. An entity that has not completed goAML registration cannot meet its CNMR or PNMR filing obligations. Both registrations must be in place before any TFS-related event can be responded to in a compliant manner.
Ownership, Control, and Acting on Behalf Of
The EOCN has published explicit guidance on the scope of the freeze obligation. Freezing measures extend beyond the directly listed person to any entity owned or controlled, directly or indirectly, by a designated individual, and to any individual or entity acting on behalf of or at the direction of a designated person. The EOCN’s position on minority interests is explicit: a simple percentage threshold is not a safe test. Where a designated person holds a minority interest but exercises effective control through appointment rights, voting arrangements, or a power of attorney, the freeze obligation applies.
CNMR reports must document the ownership and control analysis that led to the freeze decision, not merely the name match. This documentation must be sufficient to demonstrate a defensible position to the supervisory authority.
Build Your goAML TFS Reporting Programme
Local Terrorist List compliance requires both EOCN NAS registration and goAML registration, along with clear CNMR and PNMR workflows for confirmed and partial matches.
Permitted Credits to Frozen Accounts
The EOCN confirms that frozen accounts may receive credits in two limited circumstances without breaching the freeze obligation, provided the additions are themselves immediately frozen. These are interest, profits, or other earnings due on the account, and payments due under contracts or obligations concluded before the date of designation. Any such credits must be immediately frozen, and the supervisory authority and the Executive Office must be notified.
Build Your goAML TFS Reporting Programme
Local Terrorist List compliance requires both EOCN NAS registration and goAML registration, together with match-handling procedures that distinguish CNMR from PNMR scenarios. Contact goAML Registration for support with TFS reporting procedures and to ensure your CNMR and PNMR workflows meet UAE supervisory expectations.
Frequently Asked Questions
No. The CNMR must be filed on a confirmed match, meaning the institution has reviewed identity documentation and concluded that the match is genuine. A vendor-generated alert is the starting point for investigation, not the conclusion. The institution must verify the match through identity documents before filing a CNMR. False positive closures must be documented, but no CNMR or PNMR is required for a false positive.
Freezing measures cease when the de-listing takes effect, which requires UAE Cabinet approval of the SCNS proposal. Institutions must verify de-listing through the EOCN’s official channels before lifting any freeze. Reliance on media reports or third-party notifications is not sufficient. The institution should document the verification step and the date on which the freeze was lifted.
Yes. The PNMR workflow is specifically designed for the scenario where a match cannot be conclusively confirmed or dismissed. Filing a PNMR is the required response when the investigation reaches a limit and resolution is not achievable within the applicable timeline. It documents the institution’s diligence and the state of the investigation at the point of filing.