How often must UAE regulated entities screen customers against sanctions lists?
UAE targeted financial sanctions obligations require screening to be continuous and risk-based rather than a one-off check at onboarding. Reporting entities must screen new customers before establishing a business relationship, screen the parties to transactions, and re-screen their entire customer base whenever the sanctions lists are updated. Because the lists can change at any time, this effectively means daily monitoring for amendments and immediate re-screening when a change is published.
Screening must extend to related parties, beneficial owners, and persons with whom there is a direct or indirect relationship, not just the named account holder. It must also continue on weekends and public holidays where customers can still access or move funds. To support this, entities must register on the Executive Office notification system so that new designations, re-designations, and de-listings reach them promptly. A match at any point obliges the entity to freeze without delay.
Legal Reference (UAE):
· Cabinet Resolution No. 74 of 2020, Article 21(2) - requires constant verification of databases and transactions against the lists and re-screening upon any change to the lists.
· Cabinet Resolution No. 74 of 2020, Article 21(1) - requires registration on the Executive Office website to receive designation and de-listing notifications.
For more details, consult the full text of Cabinet Resolution No. 74 of 2020 or seek guidance from your AML compliance officer.