Do UAE law firms and company service providers need to screen against sanctions lists?
Yes. Firms and providers within scope must implement targeted financial sanctions and screen customers, beneficial owners and connected parties against the UAE Local Terrorist List and the United Nations Consolidated List. Screening should happen at onboarding and on an ongoing basis, because listings can change at any time.
If a confirmed match is found, the firm must freeze the relevant funds immediately, without delay and without prior notice to the customer, refrain from providing any funds or services, and report the freezing measures to the Executive Office and its supervisory authority through goAML within the required timeframe. A potential match should trigger suspension of the transaction pending resolution. Subscribing to the automatic sanctions notification alert system helps firms act inside the tight deadlines the regime demands.
Legal Reference (UAE):
· Federal Decree-Law 10/2025, Article 19(1)(e) — obligation to implement targeted financial sanctions instructions forthwith.
· Cabinet Resolution 74/2020 — regulates the terrorist lists and implementation of UN Security Council sanctions resolutions.
For more details, consult the full text of Federal Decree-Law 10/2025 or seek guidance from your AML compliance officer.