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Partial Name Match Report (PNMR)

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    Partial Name Match Report (PNMR)

    Partial Name Match Report (PNMR) is a compliance tool the UAE uses in the Anti-Money Laundering (AML) framework to make potential matches between client names and those on international sanctions or watchlists. At Vigor Accounting & Taxation, we help companies realize and report partial name matches to meet UAE AML laws and avert the facilitation of financial crimes such as money laundering or terrorism finance.

    What is a Partial Name Match Report (PNMR)?

    A Partial Name Match Report (PNMR) is a report generated when an individual or client’s name is considered similar to one that appears on a sanctions list, politically exposed person (PEP) list, or any other financial watchlists. In the case of the UAE, businesses are legally permitted to report these matches to the Financial Intelligence Unit (FIU) through the goAML platform thereby ensuring transparency and averting any involvement with persons or entities implicated in financial crimes.

    The fact that the name given partially matches is not a confirmation of a person's or entity's involvement in illegal activities, but it necessitates further inquiries into the issue at hand to establish whether indeed the focus of the name match is an individual or a business entity. A violation of such matches' reporting can lead to penalties or sanctions for the reporting organization.

    Importance of Filing a PNMR in the UAE

    Filing a PNMR is crucial for several reasons, particularly in ensuring compliance with AML regulations and preventing the misuse of the UAE’s financial systems for criminal activities.

    • Compliance with UAE Regulations

      Businesses in the UAE have a legal obligation to file a report of any dubious behavior, such as partial name matches, in accordance with the Federal Decree Law No. 20 of 2018. Such a move ensures the strict adherence to the AML laws of companies and allows businesses to escape legal consequences or penalties for not reporting.

    • Preventing Financial Crimes

      PNMRs carry a lot of significance in the detection as well as when it comes to thwarting the efforts of individuals or any organizations to exploit honest businesses to launder money or finance terrorism. The businesses can array and probe into some suspicious similar name clues that they are more likely to be inadvertently entangled in crime with.

    • Risk Mitigation

      Businesses filing PNMRs can lessen the risk of being associated with people or companies who may harm their reputation or create legal problems. The act of submitting a report shows that a company is dedicated to transparency and upholding ethical business practices, which enhances its credibility in the marketplace. This is the case with a business that submitted a report.

    When to File a PNMR

    There are several situations where a business may need to file a Partial Name Match Report (PNMR)

    01

    Close Matches to Sanctions Lists
    If a client’s name is a close but not exact match to a name on a sanctions list or watchlist.

    02

    High-Risk Clients
    If the client operates in high-risk sectors or geographic areas known for higher exposure to money laundering or terrorist financing activities.

    03

    Suspicious Financial Behavior
    When a name match is coupled with suspicious activity, such as unexplained or large transactions.

    How to File a PNMR

    At Vigor Accounting & Taxation, we assist businesses in filing PNMRs quickly and accurately. Here’s how the process works:

    01
    Identify the Partial Name Match
    The initial stage involves determining the coincidence of a customer’s name with the names in a list of sanction or monitoring. It is necessary to ensure that the solutions are capable of detecting such coincidence automatically and giving compliance officers a signal.

    02

    Submit the PNMR via goAML

    If the investigation suggests a genuine risk, a PNMR must be submitted to the FIU through the goAML platform. The report includes all the particulars about the match, the client, and the transaction or transactions which are material to the engagement. Our team assures the report is of good quality and the UAE laws are also put into the account.

    03

    Investigate the Match

    Once a match has been established, it is essential to compile supplementary information to authenticate the individual the client and ascertain if they are the target of the match. This could be done by looking for additional documentation or conducting a detailed background investigation.

    04
    Maintain Confidentiality
    Businesses may not inform the client or any third parties about the filing of the PNMR, as this might jeopardize an ongoing investigation. We guarantee that all PNMRs are lodged in a discreet and safe manner.

    Challenges in PNMR Compliance

    Many businesses face challenges in managing and filing PNMRs

    01
    Identifying True Matches
    Distinguishing between false positives and genuine matches can be complex, especially when clients have common names or operate in high-risk regions.
    02
    Keeping Up with Regulations
    AML regulations are constantly evolving, and businesses must stay updated on new requirements to remain compliant.
    03
    Ensuring Timely Reporting
    Failing to file a PNMR promptly can result in penalties, making it essential to act quickly when a match is identified.

    How Vigor Accounting & Taxation Can Help

    At Vigor Accounting & Taxation, we offer a range of services to assist businesses in managing their AML compliance obligations, including the filing of PNMRs. Our services include

    Training and Support icon

    Training and Support

    We provide training programs to help your team identify partial name matches and understand the steps involved in filing a PNMR.
    Compliance Support icon

    Compliance Assistance

    Our experts ensure that your business meets its AML obligations by implementing effective systems for identifying and reporting partial name matches.
    Filing Support icon

    Filing Support

    We handle the technical aspects of filing a PNMR through the goAML platform, ensuring that the report is accurate, timely, and compliant with UAE regulations.

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