Sanctions screening and targeted financial sanctions: the UAE regime in practice

The legal framework

Cabinet Decision No. 74 of 2020 concerning the UAE list of terrorists and the implementation of UN Security Council decisions on the suppression and combating of terrorism, terrorist financing and the proliferation of weapons of mass destruction is the instrument that gives targeted financial sanctions direct effect in the UAE. It sits alongside Federal Decree-Law No. 10 of 2025 and the Executive Regulations in Cabinet Resolution No. 134 of 2025, and every sector rulebook requires compliance with it. The Executive Office for Control and Non-Proliferation administers the regime, publishes the lists and receives the reports.

The lists

Two families. The UN Security Council consolidated sanctions list, which the UAE applies directly and without delay once the Security Council acts, and the UAE local terrorist list issued by Cabinet decision. Both are published through the Executive Office for Control and Non-Proliferation, which also operates the subscription service that notifies firms of updates. A firm that is not subscribed cannot show that it screened against the list as it stood on the relevant date, which is a finding in itself. Other countries' sanctions programmes, such as those of the United States, the European Union and the United Kingdom, are not UAE law but are relevant to risk assessment and to correspondent and counterparty relationships, and many firms screen against them for commercial reasons.

Screening scope and frequency

• Who. Customers, their beneficial owners and controllers, authorised signatories, counterparties to transactions and, for virtual asset firms, wallet addresses and counterparty VASPs where the data allows.
• When. At onboarding before any transaction, on every list update against the entire customer base, periodically as a control, and on each transaction for counterparties.
• How. Fuzzy matching calibrated to the firm's data quality, with documented thresholds, a four-eyes process for resolving potential matches, and a record of every disposition.

What happens on a match

Potential matches are resolved by comparing identifiers: name variants, date of birth, nationality, identification numbers, addresses. A confirmed match triggers three obligations in order. Freeze the funds and assets without delay and without prior notice to the person. Report the freeze, and any attempted transaction, to the Executive Office for Control and Non-Proliferation through the prescribed channel within the time the decision sets, and file with the Financial Intelligence Unit where the facts also give rise to suspicion. Do not tip off. The frozen assets remain frozen until the Executive Office directs otherwise; the firm does not decide for itself that the match was wrong after the fact.

False positives are the daily reality. The programme must show that each was resolved on evidence and by someone with authority to do so, within a defined time. A backlog of unresolved potential matches is treated by inspectors as a failure to screen.

Proliferation financing

The 2025 law brings the financing of proliferation of weapons of mass destruction expressly within the AML framework, and the sanctions regime is where it bites hardest. Dual-use goods, trade finance with high-risk corridors and shipping are the typologies. Firms in those sectors should have a proliferation financing dimension in their risk assessment and specific red flags in their monitoring.

Where we come in

We draft the sanctions section of the programme, advise on scope and frequency proportionate to the business, give legal opinions on whether a counterparty or structure is caught, manage freeze and reporting steps when a true match occurs, and handle the Executive Office and regulator correspondence that follows. See the AML compliance practice page and our DNFBP guide for the sanctions duties the 2026 Ministry circular imposes on non-financial businesses.

Frequently asked questions

What law governs sanctions compliance in the UAE?

Cabinet Decision No. 74 of 2020 implements the UN Security Council sanctions resolutions and the UAE local terrorist list, alongside Federal Decree-Law No. 10 of 2025 and its Executive Regulations. The Executive Office for Control and Non-Proliferation administers the regime.

Which sanctions lists must UAE firms screen against?

The UN Security Council consolidated list and the UAE local terrorist list, both published through the Executive Office for Control and Non-Proliferation. Other countries' programmes are not UAE law but are relevant to risk and to counterparty relationships, and many firms screen against them commercially.

What must we do if a customer matches a sanctions list?

Freeze the funds and assets without delay and without prior notice, report the freeze and any attempted transaction to the Executive Office for Control and Non-Proliferation through the prescribed channel, file with the Financial Intelligence Unit where there is also suspicion, and do not tip off. The freeze stays until the Executive Office directs otherwise.

How often must sanctions screening be run?

At onboarding, on every list update against the whole customer base, periodically as a control, and on transactions for counterparties. Firms must subscribe to the Executive Office's list update notifications and be able to show screening ran on each update.

Does a high-risk country on the FATF list mean sanctions apply?

No. FATF listing triggers enhanced due diligence and countermeasures under Article 23 of the Executive Regulations; targeted financial sanctions apply to listed persons and entities under Cabinet Decision No. 74 of 2020. The two regimes overlap in practice but have different triggers and consequences.

This article is general information on the position at the date shown and is not legal advice. AML obligations turn on the licence, the regulator and the facts of each business; speak to us before relying on it.