UAE targeted financial sanctions: what Cabinet Decision 74 of 2020 asks of you

If you are a bank, an exchange house, a real estate broker, a dealer in precious metals or a corporate service provider in the UAE, targeted financial sanctions are not a background obligation. They come with short deadlines, a named supervisory office and an expectation that you can show your working. This post sets out what UAE Cabinet Decision 74 of 2020 and the surrounding framework ask of a regulated firm, and what that means for the way you screen.

This is a practical explainer, not legal advice. The obligations below are described as published by the UAE authorities; check the current text and your supervisor’s guidance before relying on them.

What does UAE targeted financial sanctions screening cover?

The UAE framework requires attention to both UN designations and the UAE Local Terrorist List. Identify relevant customers and beneficial owners, review potential matches, retain the evidence and follow the applicable freezing, suspension and reporting process. The CBUAE’s TFS guidance links to the official instruments and current procedures.

Key takeaways

• Under UAE AML rules, regulated firms must screen against both the UN Security Council Consolidated List and the UAE Local Terrorist List, and must act on updates to either without delay.
• A confirmed match triggers a freeze without prior notice and a report to the Executive Office for Control and Non-Proliferation (EOCN), on the timelines the EOCN publishes.
• Partial and false matches carry their own reporting expectations and need to be documented, not silently discarded.
• The evidential burden sits with you: which lists you checked, when, against which version, and why you concluded what you did.

The framework in one paragraph

The current wider AML framework includes Federal Decree-Law No. 10 of 2025 and Cabinet Resolution No. 134 of 2025. The 2025 law repealed Federal Decree-Law No. 20 of 2018. Targeted financial sanctions sit alongside that regime in Cabinet Decision 74 of 2020, which regulates the UAE terrorist list and gives effect to the UN Security Council resolutions on the suppression of terrorism, terrorist financing and the financing of proliferation. The Executive Office for Control and Non-Proliferation, the EOCN, is the body that administers the lists, receives freeze and match reports and issues guidance on how firms should comply.

Who is caught? Financial institutions, designated non-financial businesses and professions (DNFBPs) and, under later measures, virtual asset service providers. The DNFBP category is wide in the UAE and includes real estate brokers and agents, dealers in precious metals and stones, auditors and accountants, lawyers and notaries when they handle certain transactions, and company and trust service providers.

Which lists you must screen

The regime points firms at two lists in particular.

The first is the UN Security Council Consolidated List, which combines the individuals and entities designated under the Council’s sanctions committees. The UAE applies these designations directly, so a change on the UN list is a change in your obligations on the day it is published.

The second is the UAE Local Terrorist List, issued by the UAE Cabinet and published through the EOCN. This list is specific to the UAE, is not mirrored on OFAC or EU feeds, and is updated by Cabinet decision. Confirm this source explicitly when evaluating a screening provider. AdverseMe parses it daily from the official file; the UAE coverage page describes how.

Screening against OFAC, the EU and the UK is not what Cabinet Decision 74 requires, and additional sanctions regimes may apply because of the parties, currencies, transaction or other jurisdictional connections. A sound programme screens the two mandatory lists and the major international feeds together. AdverseMe covers 13 official sanctions feeds alongside the five GCC and MENA national lists; the coverage page lists them.

When you must screen

The obligation is continuous, not one-off. Firms are expected to screen at onboarding, before executing transactions with a counterparty, and on an ongoing basis against the current version of each list. The EOCN publishes updates through its notification system and expects subscribed firms to re-screen their customer base when a list changes, without waiting for the next periodic review.

That last point is where most manual programmes break. A list update on a Tuesday afternoon means every existing customer needs re-checking, and a monthly refresh does not satisfy “without delay”. AdverseMe’s monitoring compares list versions and supports scheduled re-screening. Its refresh and processing schedules do not replace an obligation to act on an official notification without delay.

What happens on a match

The framework distinguishes between a confirmed match, a partial or potential match and a false positive, and each has its own path.

On a confirmed match, the freezing and reporting procedure must be ready for immediate action without prior notice. For licensed financial institutions, the CBUAE’s TFS guidance specifies a Funds Freeze Report through goAML within five business days of freezing action. Do not treat the reporting window as permission to delay freezing.

On a partial or potential match, do not silently discard the hit. The same CBUAE guidance calls for suspension of the relevant transaction and a Partial Name Match Report through goAML within five business days, pending instructions. DNFBPs should follow the current EOCN guidance and their own supervisory authority’s procedure; this article is not a substitute for sector-specific advice.

On a resolved false positive, document what was matched, what evidence ruled it out and who decided. The Engine Trace records source outcomes and excluded wrong-entity matches. Keep the analyst’s resolution and any regulatory correspondence alongside that evidence.

Arabic names and transliteration

A specific difficulty with the UAE list, and with the other national lists in the region, is that the official entries are in Arabic with Latin transliterations that vary from one publication to the next. A screening engine that matches on a single Latin spelling will miss entries; one that matches too loosely will bury the analyst in noise. AdverseMe parses the five GCC and MENA lists daily and applies Arabic transliteration handling so that variant spellings of the same name are matched, then puts the four independent judges on the result so the score reflects the evidence rather than the spelling.

Keeping the evidence

Cabinet Decision 74 and the surrounding rules put the record-keeping burden on the firm. For each customer you need to be able to show which lists were screened, on what date, against which list version, what came back, how each hit was resolved and, where relevant, what was reported to the EOCN. Supervisors and auditors ask for this per file, not per programme.

AdverseMe’s PDF report is built to be that file: a determination, findings with source evidence, coverage, excluded matches and limitations. Per-judge reasoning remains in the app. Reports are free to download on every plan.

A short checklist for DNFBPs

• Confirm you are in scope with your licensing authority and register with the EOCN’s notification system.
• Screen every customer and beneficial owner against the UN Consolidated List and the UAE Local Terrorist List, and add the major international feeds.
• Re-screen the whole book whenever either list changes, not at the next periodic review.
• Have a freeze-and-report procedure ready before the first match, with the EOCN’s current timelines written into it.
• Keep a per-customer record of what was screened, when, against which version, and how each match was resolved.

Our DNFBP use case walks through how a real estate broker or a corporate service provider runs this in AdverseMe in one screening. Plans start on the pricing page; to run your first screening against the UAE and UN lists today, get started.