PNMR Reporting Services in the UAE

What Is a Partial Name Match?

A partial name match happens when some details of your customer match a person on a sanctions list, but other details are missing or different, so you cannot say for sure whether it is them. For example, the name and year of birth match, but the nationality does not, or the listed entry has no ID number to compare.

Partial Match, Confirmed Match or False Positive?

• Confirmed match: the person is clearly the listed individual or entity. You must freeze funds and file a CNMR.
• Partial match: you cannot confirm or rule it out, even after checking ID. You must suspend and file a PNMR.
• False positive: the details show it is a different person. No report is needed, but you must keep a record of how you decided.

Which Sanctions Lists Should UAE Businesses Screen?

The UN Consolidated List and the UAE Local Terrorist List. Together these make up the UAE sanctions list for targeted financial sanctions. The EOCN publishes updates and notifies registered businesses, so your name screening should run at onboarding and every time a list changes.

UAE Sanctions Laws Behind the PNMR

Screening and partial matches are governed by the UAE's sanctions resolution and the EOCN's guidance. Note that the EOCN guidance is official guidance, not a law, but supervisors expect you to follow it.

“Implement forthwith the instructions issued by the Executive Office or any other Competent Authorities concerning Targeted Financial Sanctions.”

Federal Decree-Law No. 10 of 2025, Article 19(1)(e)

What to Do After a Partial Name Match

If the Person Is an Existing Customer

1. 01
   Check their ID documents against the listed entry.
2. 02
   If you still cannot decide, suspend any transaction and stop providing funds or services straight away.
3. 03
   File a PNMR on goAML within five business days of the suspension.
4. 04
   Keep the suspension in place until the EOCN tells you, through goAML, to lift it or to freeze.

If the Person Is a New Customer or a Counterparty

1. 01
   Try to get their identification documents.
2. 02
   If the documents show a false positive, you may proceed. Record your decision.
3. 03
   If you cannot get the documents within a reasonable time (the EOCN guidance uses 10 business days), reject the transaction.
4. 04
   File a PNMR within five business days of the rejection, explaining that ID was not provided.

Example of a PNMR Case

An exchange house screens a walk-in customer. The full name and year of birth match a UN-listed person, but the listing has no passport number and shows a different place of birth. The passport the customer shows does not settle it. The exchange house suspends the transaction, files a PNMR within five business days and waits for the EOCN's decision.

How Our PNMR Reporting Service Works

PNMRs and EOCN replies both go through goAML, so you must have an active account. We can complete your SACM registration and Google Authenticator setup in advance. For each case we:

1. 01
   Review the hit: compare names, spellings, dates of birth, nationality and ID numbers.
2. 02
   Request documents: help you collect the ID needed to settle the match.
3. 03
   Decide the outcome: confirmed, partial or false positive, with written reasons.
4. 04
   Guide the suspension: make sure funds and services are paused properly.
5. 05
   Prepare the PNMR: attach all details and documents in goAML.
6. 06
   Watch for the EOCN reply: then help you lift the suspension or move to a freeze.

How to Reduce False Positives in Sanctions Screening

• Screen using full names plus date of birth and nationality, not names alone.
• Collect clear ID copies at onboarding.
• Tune fuzzy-matching settings so they are neither too loose nor too strict.
• Keep a short written reason for every false positive you close.

Common PNMR Mistakes

• Releasing the transaction before the EOCN responds.
• Missing the five-business-day window.
• Treating a confirmed match as only a partial one.
• Screening once at onboarding and never again after list updates.
• Not keeping screening records for at least five years.

Penalties for Sanctions Breaches

Under Article 33 of Federal Decree-Law No. (10) of 2025, breaking targeted financial sanctions instructions can mean prison, a fine of at least AED 20,000, or both. For a company, Article 27(2) sets fines of AED 200,000 to AED 10,000,000, and supervisors can add administrative fines under Article 17.

Why Choose Our PNMR Reporting Services?

• Fast reviews so you stay inside the five-day deadline.
• Clear written reasons for every screening decision.
• Support until the EOCN instruction arrives and is applied.
• goAML registration and reporting under one roof.

Frequently Asked Questions