Must UAE accountants screen clients against sanctions and PEP lists?
Yes. As DNFBPs, accountants must implement targeted financial sanctions instructions immediately and must operate systems to determine whether a client or beneficial owner is a politically exposed person. Sanctions screening is not optional and must be applied at onboarding and on an ongoing basis.
Where a client or beneficial owner is a foreign politically exposed person, the firm must obtain senior management approval before starting or continuing the relationship, establish the source of wealth and funds, and apply enhanced ongoing monitoring. Domestic PEPs and those entrusted with prominent functions by international organisations are assessed on a risk basis. Any match against a UN or local sanctions list must be acted on without delay and reported as required.
Legal Reference (UAE):
· Cabinet Resolution No. 134 of 2025 (Executive Regulations), Article 16 - politically exposed person measures and senior management approval.
· Federal Decree-Law No. 10 of 2025, Article 19(1)(e) - immediate implementation of targeted financial sanctions.
For more details, consult the full text of Cabinet Resolution No. 134 of 2025 or seek guidance from your AML compliance officer.