How often must UAE entities screen customers against sanctions lists?
Screening is not a one-off onboarding task. UAE entities must screen customers, beneficial owners, and transaction parties against the UN Consolidated List and the UAE Local Terrorist List at onboarding, before executing transactions, during periodic reviews, and whenever the lists are updated. Because a designation triggers a 24-hour freezing duty, screening has to run against every list update, not just at the start of a relationship.
This flows from the targeted financial sanctions framework in Cabinet Resolution No. 74 of 2020, which requires funds to be frozen without delay under Article 15, a standard that is impossible to meet without ongoing, near real-time screening. Former customers retained in records should also be screened on list updates during the retention period. Entities commonly automate this so that new or amended listings are checked against the whole customer base immediately.
Legal Reference (UAE):
· Cabinet Resolution No. 74 of 2020, Article 15: freezing without delay requires ongoing screening.
· Federal Decree-Law No. 10 of 2025, Article 19: continuous monitoring under a risk-based approach.
For more details, consult the full text of Cabinet Resolution No. 74 of 2020 or seek guidance from your AML compliance officer.