CMA Guidance of 2026 · UAE Federal
Thematic review of sanctions and name-screening systems in the UAE capital markets sector, covering background, scope, methodology and testing results.
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.
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.
English official text in 16 provisions. Open the full text or jump to a provision:
| Section 1 | Executive 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 3 | Scope: 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 4.1 | Testing used exact-match control data, variation data (spelling, name order, Arabic-Latin transliteration) and clean data to measure detection and false positives. |
| Section 5.3 | Elevated non-relevant alert volumes were found in a number of cases, showing scope to optimise calibration and filtering logic. |
| Section 5.5 | Data quality matters: a well-configured system may miss matches where date of birth, nationality or identification details are incomplete or inconsistent. |
| Section 7 | Firms 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. |
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.
| Cites | AML/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.
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