CMA Circular No. 4/2021 of 2021 · UAE Federal
SCA notice setting the procedure for reporting targeted financial sanctions matches through the goAML platform, including the steps licensed entities must take on a confirmed match.
Notice No. 4 of 2021 sets the reporting procedure every CMA-licensed entity (then SCA-licensed) must follow when screening produces a match against the UAE Local Terrorist List or the UN Security Council Consolidated List: freeze and file a Funds Freeze Report within two business days for a confirmed match, and suspend and file a Partial Name Match Report for a potential match.
The notice is dated 4 August 2021 (reference 4-2021) and follows Notice No. 3 of 2021 of 26 July 2021. It records that the Central Bank of the UAE, with the Executive Office of the Committee for Goods and Materials Subject to Import and Export Control, set up a single mechanism for reporting targeted financial sanctions obligations through the Financial Intelligence Unit's goAML platform. goAML carries two sanctions reports, the Funds Freeze Report (FFR) and the Partial Name Match Report (PNMR), which the Executive Office and the Authority receive at the same time.
On a confirmed match, the firm must apply all measures required by Cabinet Decision No. 74 of 2020 and the related guidance without delay, report any freeze, any refusal of funds or services and any attempted transaction through an FFR within two business days, and attach all supporting information. On a potential match, the firm must suspend the transaction without delay, refrain from providing funds or services, file a PNMR with the supporting documents, and keep the suspension in place until the Executive Office instructs it, through goAML, to lift the suspension or to freeze.
The notice has no penalty clause of its own; failures fall under Cabinet Decision No. 74 of 2020 and the AML law. Later notices (5 of 2021 and 1 of 2022) applied the same reports to specific UN regimes. The timing has since changed: from 1 August 2025, Notice No. 1 of 2025 requires freezing within 24 hours of designation, renames the Funds Freeze Report the Confirmed Name Match Report, and allows five business days for both reports.
All entities licensed by the Securities and Commodities Authority (now the Capital Market Authority) and licensed securities and commodities exchanges, when name screening returns a confirmed or potential match to the UAE Local Terrorist List or the UN Security Council Consolidated List.
English official text in 3 passages. Open the full text or jump to a provision:
| Paragraph 1 | Records that the Central Bank, with the Executive Office of the Committee for Goods and Materials Subject to Import and Export Control, established a unified mechanism to report targeted financial sanctions obligations through goAML. |
| Paragraph 2 | goAML carries two sanctions reports, the Funds Freeze Report and the Partial Name Match Report, received simultaneously by the Executive Office and the Authority. |
| Paragraph 3 | On a confirmed match: implement all measures under Cabinet Decision No. 74 of 2020 and the sanctions guidance without delay, and report any freeze, refusal of funds or services or attempted transaction by FFR within two business days. |
| Paragraph 4 | On a potential match: suspend any transaction without delay, refrain from offering funds or services, file a PNMR with the supporting documents, and keep the suspension until the Executive Office instructs otherwise through goAML. |
| Paragraph 5 | Licensed entities should consult the Authority's and the Executive Office's websites and published guidelines as they are updated from time to time. |
Polaris is not licensed by the CMA and does not operate a regulated firm's sanctions controls. For clients building a CMA-licensed business, we make sure the AML/CFT policy pack, the goAML registration and the MLRO's escalation procedure reflect the FFR and PNMR routes and the two-business-day clock, and we work with the client's compliance adviser to test them. As a goAML-registered corporate service provider we follow the same freeze-and-report sequence for our own client base, so the KYC, UBO and corporate records we keep for clients are already organised the way a sanctions report requires.
| Amended by | CMA Notice No. 1 of 2025 |
| Cites | Targeted Financial Sanctions Regulation |
“Cites” and “Cited by” are built automatically from references in the full texts held in this library; they cover only instruments in the library.
Targeted Financial Sanctions Regulation
Governs the UAE Local Terrorist List and the implementation of UN Security Council sanctions: listing and delisting, the role of the Executive Office for Control and Non-…
Notice 3/2021 on Cabinet Resolution 74/2020
SCA notice to licensed entities and exchanges setting the immediate reporting mechanism for financial institutions implementing Cabinet Resolution No. 74 of 2020 on terro…
Notice 5/2021 on UNSCRs 1267, 1989 and 1988
SCA notice on sanctions under UNSC Resolutions 1267 (1999), 1989 (2011) and 1988 (2011), advising entities to apply enhanced screening to all parties to transactions.
Notice 1/2022 on TFS under UNSCRs 1718 and 2231
SCA notice to all licensed entities and exchanges on implementing targeted financial sanctions under UNSC Resolutions 1718 (2006) and 2231 (2015).
Notice 1/2025 on enhanced TFS obligations
Notice on enhanced obligations under the UAE targeted financial sanctions guidance updated on 1 August 2025.
AML/CFT/CPF Law 2025
The UAE's principal AML law in 42 articles. It criminalises money laundering, terrorism and proliferation financing, imposes risk assessment, customer due diligence, reco…
Thematic Review of Screening Systems (Capital Markets, 2026)
Thematic review of sanctions and name-screening systems in the UAE capital markets sector, covering background, scope, methodology and testing results.
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