CNMR Reporting Services in the UAE

What Is a CNMR?

A CNMR tells the Executive Office for Control and Non-Proliferation (EOCN) that you found a confirmed match with the UN Consolidated List or the UAE Local Terrorist List, and explains what you did about it: froze funds, rejected a deal, or both. It replaced the older Funds Freeze Report (FFR), so you may still hear that name.

When Is a Match "Confirmed"?

A match is confirmed when the identifying details, such as full name, date of birth, nationality and passport or ID number, line up with the listed person or company, leaving no reasonable doubt. If doubt remains, it is a partial match and the PNMR process applies instead.

UAE Laws on Freezing Funds and Filing a CNMR

A confirmed match triggers some of the strictest rules in UAE financial law. These provisions set out what you must do, and how fast:

“Any person; without delay and without prior notice; shall freeze funds under the Sanctions List and the Local Lists”

Cabinet Resolution No. 74 of 2020, Article 15(1)

Step-by-Step: What to Do With a Confirmed Match

For an Existing Customer

1. 01
   Freeze within 24 hours: block accounts, balances, deposits and any other assets you hold.
2. 02
   Stop all services: do not make any funds or services available to the person.
3. 03
   Do not warn them: freezing comes without prior notice.
4. 04
   File a CNMR within five business days of the freeze.

For a New Customer or a Counterparty

1. 01
   Reject the transaction and refuse any funds or services.
2. 02
   Freeze anything already received.
3. 03
   File a CNMR within five business days of the rejection, explaining what you did.

Do Not Forget Past Relationships

The EOCN guidance asks for CNMRs on past dealings with the designated person going back five years, including closed accounts, even if you hold nothing today. Say clearly in the report that no funds are currently held.

What Must Be Attached to a CNMR?

• The full name of the matched person or company, with ID documents (passport or ID card; trade licence and articles of association for companies).
• The value of everything frozen, with proof such as bank statements, receipts, title deeds or policy documents.
• A description of the rejected deal or service where no funds are held.

CNMR Example

After a list update, a property brokerage re-screens a buyer in a pending deal. The name, date of birth and passport number all match an entry on the UAE Local Terrorist List. The brokerage stops the sale, freezes the deposit it holds within 24 hours and files a CNMR within five business days, attaching the ID copy, the deposit receipt and a short description of the cancelled deal.

How Our CNMR Reporting Service Works

CNMRs can only be filed from your own goAML account, created through the FIU's SACM portal. With that in place, we:

1. 01
   Confirm the match: double-check every identifier against the listed entry.
2. 02
   Coordinate the freeze: help you act within 24 hours without alerting the customer.
3. 03
   List the assets: account for every balance, product and related asset.
4. 04
   Check five years back: search past records for the designated person.
5. 05
   Prepare the CNMR: with all mandatory attachments, inside five business days.
6. 06
   Liaise: help you respond to the EOCN and your supervisor.

Frequent CNMR Mistakes

• Waiting for internal sign-offs and missing the 24-hour freeze window.
• Letting the customer know before the freeze is in place.
• Freezing one account but missing other products or related entities.
• Skipping the five-year look-back.
• Filing a PNMR when the match is actually confirmed.

Penalties for Sanctions Violations

Sanctions failures are treated as crimes. An individual can be jailed, fined twenty thousand dirhams or more, or both (Article 33 of the AML law), a company can be fined between AED 200,000 and AED 10 million (Article 27(2)), and the supervisor may add penalties of up to AED 5 million per breach (Article 17). Separately, anyone who breaches a freezing order issued by a competent authority faces prison, a fine of at least AED 50,000, or both (Article 29(2)).

Why Choose Our CNMR Reporting Services?

• Same-day guidance when a confirmed match appears.
• Complete reports with every required attachment.
• A full five-year look-back on past relationships.
• Help with EOCN and supervisor communication.

Frequently Asked Questions