Must UAE lawyers and TCSPs screen clients against sanctions and terrorist lists?

UAE
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Yes. Law firms and TCSPs must implement, without delay, the instructions issued by the Executive Office and other competent authorities on Targeted Financial Sanctions. In practice this means screening clients and beneficial owners against the UAE Local Terrorist List and the United Nations Consolidated List, both at onboarding and on an ongoing basis when the lists are updated.

If a match is found, the firm must freeze any funds without delay, refrain from dealing with the designated party and report to the supervisory authority and the Executive Office as required. DNFBPs are expressly named among the entities that must apply these freezing measures and report. Screening should be repeated when sanctions lists change, not only at the start of a relationship, and the firm should keep evidence of the screening it performs. Failure to apply sanctions measures is treated as a serious violation. Firms should subscribe to the Executive Office notification system so that list updates reach the compliance officer promptly, and calibrate their screening to catch name variations and partial matches rather than exact spellings alone.

Legal Reference (UAE):

For more details, consult the full text of Cabinet Resolution No. 74 of 2020 or seek guidance from your AML compliance officer.

AML regulations for TCSPs in UAE

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Yes. Cabinet Resolution No. 74 of 2020 imposes the screening obligation on financial institutions and designated non-financial businesses and professions alike, and lawyers, notaries, other independent legal professionals and company and trust service providers are DNFBPs when carrying on the listed activities.

The screening obligation is broad. It requires constant verification of databases and transactions against the lists issued by the Security Council, the Sanctions Committee and the UAE local lists, covering the customer database, parties to any transaction, potential clients, the real beneficiaries, and persons and organisations with a direct or indirect relationship, and searching again before performing any operation or entering a business relationship. On a match, freeze without delay and without prior notice, and report.

Legal Reference (UAE):

· Cabinet Resolution No. 74 of 2020, Article 21: obligations imposed identically on financial institutions and DNFBPs, including the categories to screen and freezing without delay.

· Federal Decree-Law No. 10 of 2025, Article 19(1)(e): implement TFS instructions forthwith; Article 33: the penalty for violating them.

For your own circumstances, check your internal AML policy or speak to your compliance officer.

Sanctions screening services