Many DNFBPs believe that checking a customer against "World-Check" or the "UN Consolidated List" is sufficient. It is not. Ignorance of the UAE Local Terrorist List is a primary cause for heavy fines under Cabinet Resolution No. 74 of 2020.
The Local List vs. UN List
The UAE Cabinet issues its own autonomous list of designated individuals and entities. These names may NOT appear on international lists immediately. You have a legal obligation to register with the Executive Office for Control and Non-Proliferation (EOCN) to receive immediate email notifications of updates.
The "Fuzzy Matching" Trap
Criminals rarely use their exact legal name. Your screening software must handle "fuzzy matching" (spelling variations). If "Mohammed Ali" is sanctioned, your system must flag "Mohamed Aly" or "M. Ali".
Immediate Action: Freezing Funds
If you find a confirmed match, you must freeze funds immediately (within 24 hours) without prior notice to the customer. You must then report this via the Fund Freeze Report (FFR) in goAML, separate from an STR.
Author: Zeej Strategic Consulting Research Team