What Is Sanctions Screening?
Sanctions screening is the practice of screening persons, entities, transactions, vendors and related parties against approved restricted lists. It prevents engaging with sanctioned individuals or organisations associated with terrorism financing, proliferation of weapons of mass destruction or other prohibited activities.
In the UAE, this is a legal requirement. Regulators expect real-time or near real-time screening, risk-based monitoring and prompt action in regards to related matches.
Non-compliance will result in significant penalties, freeze of funds, licence revocation, reputational harm and, in the case of violations under the new AML laws, also carry criminal exposure.
Key Sanction screening lists that every business in the UAE is required to screen against:
- UAE Local Terrorist List (issued by the Cabinet)
- UN Security Council Consolidated List
- OFAC (US), EU, UK and any other lists that are applicable based on the risk profile of your organisation and its activities.
Our Comprehensive Sanctions Screening Services in Dubai
We provide end to end comprehensive sanctions screening and verification services for UAE businesses:
- Real time and batch screening: We screen new clients, existing clients, ultimate beneficial owners (UBOs), directors, authorised signatories, counterparties and transaction parties on the latest local and international sanctions, watchlists and Political Exposed Persons (PEPs).
- Continuous monitoring and daily re- screening: Our professionals continuously monitor sanctions lists and re-screen your clients with automated notifications to ensure you stay fully protected with any sanctions designation.
- Enhanced Due Diligence (EDD) in cases of high risk matches: We investigate all potential matches and resolve false positives, establish the level of risk and prepare full documentation ready for audit.
- Transaction screening: We screen payments instructions, remittances, trade finance and other transactions before they are executed.
- Assist with Policy, procedures and systems: We assist you with building or establishing your sanctions screening and compliance system, design escalation and freeze procedures and provide training to your staff to fulfil requirements of the Central Bank of UAE (CBUAE) and the Executive Office for Control & Non-Proliferation (EOCN).
- Reporting and freeze support: We assist with Fund Freeze Reports (FFR) via goAML, notifications to the EOCN and provide audit ready reporting.
Relevant UAE Laws and Regulatory Requirements
Our services are in full compliance with the applicable legal regime, which includes:
- Cabinet Decision No. 74 of 2020 – Regulation of Terrorism Lists and the Implementation of UN Security Council Resolutions (the core rules concerning screening, “freezing without delay” within 24 hours, and the responsibilities of financial institutions and DNFBPs).
- Federal Decree-Law No. 10 of 2025 on Anti-Money Laundering, Combating the Financing of Terrorism, and Proliferation Financing (the updated primary AML/CFT/PF law, which improves screening, monitoring, and penalty regimes).
- CBUAE Rulebook requirements for screening of sanctions (real-time sanction screening of parties to transactions, ongoing testing of systems, escalation procedures, and record-keeping).
- Guidance from the Executive Office for Control & Non-Proliferation (EOCN) on Targeted Financial Sanctions.
- FATF Recommendations and relevant UAE implementing measures.
Screening should be carried out prior to onboarding, before executing transactions, on an ongoing basis, and when lists are updated. Confirmed matches must be subjected to immediate freezing of funds without notification and prompt reporting.
Targeted Financial Sanctions (TFS) Compliance
Under UAE law, each business is required to apply Targeted Financial Sanctions (TFS) immediately. This is one of the most strictly enforced parts of the sanctions regime.
The main TFS obligations are:
- Screen all customers, beneficial owners, directors, authorised signatories and transaction parties using the UAE Local Terrorist List and the UN Security Council Consolidated List.
- Screen before onboarding, before each transaction, on an ongoing basis and immediately whenever the lists are updated.
- Freeze all funds and assets in 24hrs (without prior notice) if you have a confirmed match.
- Report both confirmed matches and partial matches in the goAML system within the required period.
- Never provide any funds, assets or services (directly or indirectly) to any designated person or entity.
Who Needs Sanctions Screening Services in the UAE?
- Banks, exchange houses, and other licensed financial institutions
- Virtual Asset Service Providers (VASPs)
- Designated Non-Financial Businesses and Professions (DNFBPs) – real estate agents, precious metals & stones dealers, lawyers, accountants, company service providers, auditors
- Corporate groups with cross-border trade, supply chain, or international clients
- Free-zone and mainland companies with high-risk jurisdictions or counterparties.
Why Choose RH and Hale Law Firm for Sanctions Screening in Dubai
At RH and Hale Law Firm in Dubai, we provide sanctions screening services in UAE for financial institutions, DNFBPs, VASPs, corporates and professional firms. Our experts screen your clients, counterparties, beneficial owners and transactions against the most up to date national and international sanctions lists, helping you fully comply with UAE and international regulations.
- Extensive local knowledge of UAE AML/CFT and targeted financial sanctions, combined with practical commercial advice.
- We provide transparent, risk-based recommendations that lower the number of false positives while achieving regulatory compliance.
- Assistance that seamlessly integrates with your existing KYC/CDD processes and technology.
- Practical compliance that protects your licence, reputation, and ability to bank and trade internationally.
- Transparent process and ongoing advisory to keep you audit-ready.
Our Simple Process
- Initial risk and gap assessment of your current screening arrangements.
- Screen solution, technology recommendations and market proposals based on your needs.
- Build-up support, configuration and staff guidance.
- Ongoing Monitoring, alert handling advice and regulatory reporting support.
- Regular reviews when the legal requirements or your risk profile changes.
FAQ
Is sanctions screening mandatory in the UAE?
Yes. Under Cabinet Decision No. 74 of 2020 and Federal Decree-Law No. 10 of 2025, financial institutions, VASPs and DNFBPs are required to screen against the UAE Local Terrorist List and the UN Consolidated List (and other sanctions lists depending on the risk).
Which sanctions lists must businesses in Dubai/UAE screen against?
At a minimum the UAE Local Terrorist List and the UN Security Council Consolidated List. Depending on your type of activity and risk profile you may also be required to screen against other sanctions lists such as OFAC (US), EU, UK, etc.
How frequently should sanctions screening be performed?
Before onboarding a new client, before any transaction, on an ongoing/daily basis for existing relationships, immediately when the lists get updated and during periodic KYC/CDD reviews.
What happens if there is a match on a sanctions list?
Immediately freeze all funds and other assets under your control (without delay and without prior notice). Without delay means within 24 hours of the decision becoming a final listing. Report via goAML (Fund Freeze Report) and inform the relevant authorities. Do not provide any information to the customer.
What are the penalties for non-compliance with sanctions screening?
Financial penalties for non-compliance can reach AED 5 million. For companies involved in serious offences (money laundering, terrorism financing or proliferation financing), fines can go up to AED 100 million (or the value of the illegal funds).
Other penalties include licence suspension or cancellation, management bans, criminal charges for the company and key staff, and damage to reputation.
