UAE targeted financial sanctions are set by Cabinet Decision No. 74 of 2020 and run by the Executive Office for Control and Non-Proliferation. Persons in the UAE, including regulated and non-regulated businesses, must follow the Local Terrorist List and the UN Consolidated List, freeze funds of listed persons without delay and report matches. Confirm current duties with the EOCN.
What targeted financial sanctions are
Targeted financial sanctions freeze the assets of named persons and bar dealing with them. The UAE applies two lists: the Local Terrorist List issued by the Cabinet and the UN Security Council Consolidated List. A named person may be an individual, a company or a group. The aim is to stop funds or services reaching them. This differs from a trade embargo on a whole country; the UAE does not publish a general list of sanctioned countries for businesses to follow, and business owners should check which regime applies to their trade.
Who has duties
Commentary on Cabinet Decision 74 of 2020 says the duties fall on all natural and legal persons in the UAE, with extra obligations on financial institutions, designated non-financial businesses and professions, and virtual asset service providers. The EOCN publishes guidance that is updated from time to time, so use the latest version. The AML legal framework itself has been updated in recent years; one summary reports a new federal decree-law in 2025 with implementing regulations. Check the legislation portal for what is in force.
Practical steps
- Register. Sign up with the EOCN notification system to receive alerts when lists change.
- Screen. Check customers, owners, directors and counterparties against the lists before onboarding and before large transactions, and repeat on a regular schedule.
- Freeze. If you hold funds or assets of a listed person, freeze them without delay.
- Report. Report the match through the channel the EOCN specifies, which for regulated entities has been goAML.
- Do not tip off. Staff must not tell the customer about the freeze beyond what the rules allow.
- Record. Keep the screening evidence and decisions.
What to screen
| Who | When |
|---|---|
| New customers and their owners | Before onboarding |
| Suppliers and agents | Before first payment |
| Existing customers | On list updates and at set intervals |
| Employees and directors | On appointment and periodically |
| Payment beneficiaries | Before release of funds |
Penalties
Commentary reports fines of up to AED 5 million under Cabinet Decision 74 of 2020 for breaches, and potential criminal liability. Confirm the figures in the legislation. Regulators can also act on firms that fail to maintain adequate controls, so a written policy and screening log matter. See AML fines for DNFBPs.
A proportionate approach for small businesses
A small company does not need an expensive system. It needs a written procedure, a named person responsible, a screening step in onboarding and a simple log. Keep screening evidence with the customer file and review the procedure once a year.
Related reading
See what the FATF decision changed and UBO register requirements. We do not provide legal sanctions advice; for a complex match, speak to a lawyer.
Examples of when screening matters
A trading company onboarding a new distributor should check the distributor, its owners and its directors before shipping. A real estate agent receiving a large payment should check the buyer and the source of funds. A service firm hiring a new director should check that person. A payment to a new overseas supplier should be screened before release, along with the supplier's owners where known. In each case the check is quick if the data is in order and expensive if it is done after the money has moved.
Partial matches and false positives
Name matches are common. A person with the same name as a listed individual is not necessarily the listed person. Compare date of birth, nationality, address, passport numbers and other identifiers against the list entry. Record why you concluded that a match was false. If you cannot rule it out, escalate to your compliance lead and follow the EOCN guidance on suspected matches, which may include freezing and reporting while the position is resolved.
Keeping evidence
- The date and time of each screening, and which lists and version were used.
- The names and identifiers checked.
- The result and the decision taken, with the name of the reviewer.
- Notes on false positives and the reasoning behind them.
- Copies of any reports made.
Other sanctions regimes
The UAE regime is built around named persons. Foreign sanctions can still affect you, for example through a bank's policies, a USD payment or a counterparty in another country. Many UAE banks apply international sanctions rules to their customers, so a trade with a restricted party can end with a frozen payment or a closed account even when UAE law does not prohibit it. Ask your bank about its policy before you enter a new market.
Training and governance
Train staff who onboard customers and approve payments. Hold a short refresher once a year, record attendance and update the procedure when the lists or the rules change. See ESR and UBO filing for how ownership data supports screening.
When to involve a lawyer
Sanctions law is a legal field with criminal consequences. If you identify a possible match, a complex ownership chain or a transaction that a bank has blocked, speak to a lawyer who works on UAE sanctions. A tax or accounting adviser can help you document your procedure and records, but should not be your only line of advice on a live match.
Group and franchise structures
A group with subsidiaries in several countries should align its screening procedure so that every entity uses the same lists and escalation path. A franchisee or agent who sells your products should be screened at appointment and periodically after that. Add a sanctions clause to contracts so you can suspend or end the relationship if a party is listed.
Annual review
Review the procedure once a year. Check that the named responsible person is current, the screening tool is still adequate, the registrations are active and staff have been trained. Keep a record of the review. Regulators ask for evidence that the procedure is operating, not only that it exists.
Frequently asked questions
Freezes on the assets of persons named on the Local Terrorist List or the UN Consolidated List, with a bar on dealing with them.
Commentary says all persons in the UAE, with extra duties for financial institutions, DNFBPs and virtual asset service providers.
Guidance expects businesses to register to receive notifications about list changes. Confirm the current requirement with the EOCN.
Freeze without delay, do not tip off the customer and report through the channel the EOCN specifies.
Before onboarding and before significant payments, and again when lists are updated or at regular intervals set in your procedure.
The UAE regime is based on named persons, not a general country list. Other regimes, such as partners' sanctions, may still affect your trade.