How quickly must a UAE business freeze funds after a sanctions designation?
Without delay, which UAE law defines precisely. Cabinet Resolution No. 74 of 2020 Article 1 defines without delay as immediately, and in any case within 24 hours of the listing decision issued by the UN Security Council, the relevant Sanctions Committee, or the UAE Cabinet. Article 15 then requires any person to freeze the funds of a designated party within that window, without prior notice to the customer.
The freeze covers funds owned or controlled in whole or in part, directly or indirectly, by the designated person, together with funds derived from them. Providing money or services to the designated party is prohibited except with the Executive Office’s permission. After freezing, the entity must notify the Executive Office within five working days. To meet the 24-hour standard, entities need automated screening that runs against list updates, not only at onboarding, so a new designation is caught the same day.
Legal Reference (UAE):
· Cabinet Resolution No. 74 of 2020, Article 1: without delay means within 24 hours of listing.
· Cabinet Resolution No. 74 of 2020, Article 15: obligation to freeze without prior notice.
For more details, consult the full text of Cabinet Resolution No. 74 of 2020 or seek guidance from your AML compliance officer.