National Competent Authorities
The Executive Office for Control and Non-Proliferation is the national competent authority for sanctions and export controls in the UAE.
Legislation
Decree Federal Law No. 20 of 2018 on Anti-Money Laundering and Combating the Financing of Terrorism and Illegal Organizations
Cabinet Decision No. 10 of 2019 Concerning the Implementing Regulation of Decree Federal Law No. 20 of 2018 on Anti-Money Laundering and Combating the Financing of Terrorism and Illegal Organizations
Cabinet Resolution No. 74 of 2020 Concerning the Local Terrorist List of terrorists and implementation of UN Security Council decisions relating to preventing and countering financing terrorism and leveraging non-proliferation of weapons of mass destruction, and the relevant resolutions.
Sanctions Lists
Guidance
Executive Office for Control & Non-Proliferation – Targeted Financial Sanctions
Executive Office for Control & Non-Proliferation – FAQs
Targeted Financial Sanctions Implementation Guidelines for Fis, DNFBPs, and VASPs
Targeted Financial Sanctions Guideline For The Insurance Sector
Simple Guideline for Targeted Financial Sanctions
Committee for Goods & Materials subjected to Import & Export Control – Targeted Financial Sanctions, Proliferation, & Terrorism Financing
Counter-proliferation financing guidelines
Guidance for LFI on the implementation of Targeted Financial Sanctions
Licensing
An individual or entity listed in the Local List, or legal representative or stakeholder may submit to the Executive Office a written request for accessing all or part of frozen funds which will be referred to the Ministry of Justice. Send the request form to iec@uaeiec.gov.ae.
Following coordination with the Supreme Council, the Ministry of Justice may approve the use of part of the frozen funds of an individual or legal entity listed in Local List for any of the following purposes:
- To cover necessary or basic expenses, such as foodstuffs, rent, mortgage, medicine, medical treatment, insurance, educational and judicial fees, and public utility fees.
- To pay professional fees and costs relating to rendered legal services and other exceptional expenses within reasonable limits, or services relating to safekeeping or management of frozen funds.
- Extraordinary expenses if and as approved, on a case-by-case basis, by the Ministry of Justice.
The Executive Office will notify the applicant in writing of the outcome of the decision related to the approval or rejection of the request.
If the application is rejected or remains without response for 30 days from the date of its submission, the applicant may file a claim with the UAE court.
Enforcement
Any person, found to violate and/or be in non-compliance with the obligation in Cabinet Resolution No. 74 of 2020 or failing to implement procedures to ensure compliance may face imprisonment of no less than 1 year and no more than 7 years and/or a fine of no less than AED 50,000 and no more than AED 5,000,000.
Supervisory authorities can impose appropriate administrative sanctions, including warning letters and license cancellations, when there is a violation or shortcoming in implementing sanctions obligations.
Individuals and entities are exempt from liability resulting from freezing funds if they in good faith believe that the freezing was necessary for the purpose of complying with Cabinet Resolution No 74, even if it later turns out that the freezing was not required by the Resolution.
Reporting
Financial institutions, designated non-financial businesses and professions, and virtual asset service providers must report any freezing or suspension measures taken upon identifying confirmed or partial name matches through the goAML platform within 5 business days from taking such measures.
Any suspicious transactions or activities that do not include confirmed or partial name matches to the UAE Local Terrorist List or UN Consolidated List should be reported to the FIU by raising a Suspicious Transaction / Suspicious Activity Report. Cases that involve a confirmed or partial name matches to the UAE Local Terrorist List or UN Consolidated List should be reported to the Executive Office by raising a Fund Freeze / Partial Name Match Report.
FIs, DNFBPs, or VASPs may credit frozen accounts with interest or other earnings on those accounts; or with payments due under contracts, agreements, or obligations that were concluded or arose before the date on which the individual or entity was designated, provided that any additions to such accounts shall also be frozen. The Executive Office and the relevant Supervisory Authority must be notified about such transactions by submitting a Fund Freeze Report through goAML with information and supporting documentation on the additional amounts added to the account.
Export controls
De-listing
Any individual or entity listed in Local List may submit, in person or through a legal representative, a claim for de-listing to the Executive Office attaching all documents supporting the claim. Send the request to: iec@uaeiec.gov.ae using this form.
The Executive Office shall refer the claim to the Supreme Council, and both may request clarifications and further documentation from the applicant, or the Law Enforcement Authorities or other relevant agencies in the State.
If the Supreme Council determines that there are no longer reasonable grounds for continuing the listing, the Supreme Council shall propose to the Cabinet that the individual or entity in question is de-listed. In case of approval by the Cabinet, the name of the listed individual or entity shall be removed from the Local List and the freezing and other measures taken by the listing decision shall be automatically lifted. The Supreme Council shall send the de-listing decision immediately to the Executive Office for publication.
The Executive Office shall be notified by the Supreme Council in case the application was rejected and shall also be notified of the Cabinet’s decision on the claim so that the Executive Office may notify the applicant.
If the claim is rejected or remains unresolved for 60 days from the date of its submission, the applicant may challenge the Cabinet’s listing decision before the UAE Court.
If a claim is rejected by the court, a new claim may only be submitted after the lapse of 6 months from the date of rejection of the previous claim unless a serious reason acceptable to the chairman arises before the expiry of such period.
De-listing guidance in Targeted Financial Sanctions Implementation Guidelines
Judgments
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American International Group Ltd., et al v Qatar Insurance Co., [2024] DIFC CA 008
