What must regulated entities do about targeted financial sanctions under UAE AML law?
Federal Decree-Law No. 10 of 2025 requires financial institutions, DNFBPs and virtual asset service providers to implement, without delay, the instructions issued by the Executive Office and other competent authorities concerning targeted financial sanctions. In practice this means screening customers, beneficial owners and transactions against the United Nations Security Council consolidated list and the UAE Local Terrorist List, and freezing without delay any funds of a listed party.
Violating targeted financial sanctions instructions is a criminal offence punishable by imprisonment and a fine of not less than AED 20,000, or either penalty, and where it jeopardises state security it is treated as an offence affecting national security. Entities should maintain automated, real-time screening, clear escalation procedures, and prompt reporting to the relevant authority. Sanctions compliance is time-critical, so delays in listing updates or freezing can themselves constitute a breach.
Legal Reference (UAE):
· Federal Decree-Law No. 10 of 2025, Article 19(1)(e) and Article 33 — require immediate implementation of targeted financial sanctions and penalise breaches
· CBUAE Targeted Financial Sanctions — official TFS guidance
For more details, consult the full text of Federal Decree-Law No. 10 of 2025 or seek guidance from your AML compliance officer.