What happens when a customer is a confirmed match on the UAE sanctions list?
When screening confirms that a customer, related party, or beneficial owner is a person or entity designated on the UN Consolidated List or the UAE Local Terrorist List, the reporting entity must act immediately. It must freeze all relevant funds without delay and without prior notice to the customer. The freeze extends to funds owned or controlled by the designated party, directly or indirectly, and to funds derived from them. The entity must not make any funds, services, or economic resources available to the designated party.
Within five working days of the freeze, the entity must notify the Executive Office by filing a Fund Freeze Report and must also report the match to its supervisory authority. If the subject is a prospective customer, onboarding must be refused. The freeze remains in place until the person is de-listed or the Executive Office authorises otherwise. Tipping off the customer about the freeze is prohibited.
Legal Reference (UAE):
· Cabinet Resolution No. 74 of 2020, Article 15(1) and (2) - requires freezing without delay and notification to the Executive Office within five working days.
· Cabinet Resolution No. 74 of 2020, Article 21(3), (5), and (7) - requires freezing on a match, reporting to the supervisory authority, and prohibits tipping off about the freeze.
For more details, consult the full text of Cabinet Resolution No. 74 of 2020 or seek guidance from your AML compliance officer.