Thematic Review of Screening Systems (Capital Markets, 2026)

CMA Guidance of 2026 · UAE Federal

Official title
Thematic Review of Screening Systems in the UAE - Capital Markets Sector 2026
Arabic title
مراجعة موضوعية لأنظمة الفحص في دولة الإمارات العربية المتحدة - قطاع أسواق المال 2026
Instrument
CMA Guidance of 2026
Issued by
Capital Market Authority
Jurisdiction
UAE Federal
Status
unknown
Topics
AML / CFT · Sanctions
Official source
legislation.uaecma.gov.ae · official text (PDF)
Full text
English official text — 16 provisions, 2,163 words, from the official text
Verified
31 October 2026
Print

Thematic review of sanctions and name-screening systems in the UAE capital markets sector, covering background, scope, methodology and testing results.

Summary

The Capital Market Authority's 2026 Thematic Review of Screening Systems tested 46 name and transaction screening systems at 26 licensed financial institutions in the capital markets sector. It found that screening is in place everywhere, but performance falls away on spelling and transliteration variants and alert volumes are often too high. The review sets the CMA's expectations for calibration, independent testing and governance.

It was carried out under the CMA's risk-based supervision and in line with Federal Decree-Law No. 10 of 2025, its Executive Regulation and FATF standards. The scope covered name screening at onboarding and on an ongoing basis (customers, beneficial owners and related parties) and transaction screening of payment flows, mainly against the UN Security Council lists and the UAE local terrorism and sanctions lists (Section 3).

Testing used three datasets (Section 4.1): exact matches to measure baseline detection, variations such as spelling differences, alternative name order and Arabic-Latin transliteration, and clean data to measure false positives. Systems generally caught clear matches but varied on complex ones. Elevated volumes of non-relevant alerts pointed to poor calibration, and governance differed in how far senior management used performance data (Sections 5.1 to 5.4). Incomplete customer data, such as date of birth, nationality or identification details, can defeat even a well-configured system (Section 5.5).

Section 7 sets the expectations. Firms must keep systems calibrated to their risk profile and remain fully accountable even when they use a vendor. They must test regularly and independently with documented evidence, review system performance at senior management or committee level (for example quarterly), maintain timely list updates and data quality, and train staff. The CMA may ask for evidence of performance, testing and remediation. The review sets no penalties of its own.

Who it applies to

Licensed financial institutions in the UAE capital markets sector supervised by the Capital Market Authority, including those using vendor-supplied name or transaction screening systems, their compliance functions and senior management.

Contents

English official text in 16 provisions. Open the full text or jump to a provision:

  1. 1 — Executive Summary
  2. 2 — Background and Regulatory Context
  3. 3 — Scope and Coverage
  4. 4 — Methodology and Testing Approach
  5. 4.1 — Testing Design
  6. 4.2 — Performance Measurement
  7. 4.3 — Benchmarking and Analysis
  8. 5 — Key Findings
  9. 5.1 — Name Screening Systems
  10. 5.2 — Transaction Screening Systems
  11. 5.3 — System Efficiency and False Positives
  12. 5.4 — Governance and Oversight
  13. 5.5 — Data, Systems, and Technology
  14. 6 — Sectoral Insights and Development Trends
  15. 7 — Supervisory Expectations
  16. 8 — Conclusion

Key provisions

Section 1Executive summary: screening is widely implemented, clear matches are generally detected, but performance varies on complex matching and alert volumes are elevated in several cases.
Section 3Scope: 26 licensed institutions and 46 screening systems, covering name screening of customers, beneficial owners and related parties and transaction screening, mainly against UN and UAE lists.
Section 4.1Testing used exact-match control data, variation data (spelling, name order, Arabic-Latin transliteration) and clean data to measure detection and false positives.
Section 5.3Elevated non-relevant alert volumes were found in a number of cases, showing scope to optimise calibration and filtering logic.
Section 5.5Data quality matters: a well-configured system may miss matches where date of birth, nationality or identification details are incomplete or inconsistent.
Section 7Firms must keep systems calibrated, stay fully accountable despite vendor reliance, test independently with documentation, review performance at senior level (for example quarterly), maintain list updates and train staff.

Obligations and deadlines

  • Calibrate and tune screening systems to the firm's risk profile.
  • Conduct regular, independent, documented testing, including after system changes.
  • Review screening performance and testing outcomes at senior management or committee level, for example quarterly.
  • Maintain timely sanctions list updates and complete customer identification data.

In practice — how Polaris handles it

Polaris is not licensed by the CMA. The review's point on data quality is where our work meets it: screening fails when names, dates of birth, nationalities and ID numbers in the customer record are incomplete or transliterated inconsistently. In the corporate and UBO records we maintain for clients, we record names exactly as on passports, with transliteration variants and full identifiers, so that the regulated institutions our clients bank and invest with can screen them accurately. We screen our own client base against UN and UAE lists to the same standard.

History and citations

CitesAML/CFT/CPF Law 2025

“Cites” and “Cited by” are built automatically from references in the full texts held in this library; they cover only instruments in the library.

Related instruments

Related Polaris services

Source and verification. This record was written from the official text published at legislation.uaecma.gov.ae, read on 31 October 2026. Quoted from that text: “The review covered 26 Licensed Financial Institutions (LFIs) and assessed 46 screening systems, encompassing both name and transaction screening frameworks.”
Published for general information by Polaris Corporate Services FZ-LLC, a licensed Trust and Corporate Service Provider. It is not legal advice and does not replace the official text, which prevails in case of difference. Arabic is the authoritative language of UAE federal and emirate legislation; English translations are provided by the issuing authorities. Instruments change: check the status and the official source before relying on this page.

Begin a Conversation

Whether you are establishing a new venture, restructuring an existing enterprise, or exploring residency pathways — we are here to advise.

Arrange a Consultation →