What does freezing without delay mean under UAE targeted financial sanctions?
Freezing without delay is one of the defining obligations of the UAE targeted financial sanctions regime. When a reporting entity identifies a confirmed match between a customer, related party, or beneficial owner and a name on the UN Consolidated List or the UAE Local Terrorist List, it must freeze all relevant funds immediately, without any prior notice to the designated person. The freeze is not limited to funds tied to a specific act; it covers funds owned or controlled, directly or indirectly, by the designated party and funds derived from them.
UAE law defines without delay precisely. It means within 24 hours of the listing decision issued by the UN Security Council, the relevant Sanctions Committee, or the UAE Cabinet. Internal approval processes cannot be used to postpone the freeze. After freezing, the entity must notify the Executive Office within five working days and must not make funds or services available to the designated party.
Legal Reference (UAE):
· Cabinet Resolution No. 74 of 2020, Article 1 - defines Without Delay as within 24 hours of the listing decision.
· Cabinet Resolution No. 74 of 2020, Article 15(1) and (3) - requires freezing without delay and without prior notice and prohibits making funds available to designated persons.
For more details, consult the full text of Cabinet Resolution No. 74 of 2020 or seek guidance from your AML compliance officer.