Step 2: Implementing an Effective Sanctions Screening Process

1. Conduct Regular Customer & Transaction Screening

• Use automated sanctions screening tools to check customer names and transactions against updated sanctions lists.

• Conduct screening at key touchpoints: onboarding, periodic reviews, and transaction execution.

• Monitor high-risk industries such as finance, real estate, trade, and crypto assets.

2. Maintain Up-to-Date Sanctions Lists

• Subscribe to real-time updates from UAE and international authorities.

• Regularly update internal databases with newly designated sanctioned entities.

UAE FIU sanctions list updates

3. Report Matches & Freeze Assets Immediately

• If a match is identified, report it to the UAE FIU via GoAML within 24 hours.

• If required, freeze funds and assets linked to sanctioned individuals/entities.

• Notify the Executive Office for Control & Non-Proliferation (EOCN) for guidance on handling frozen assets.

How to report a match

4. Train Your Compliance Team & Staff

• Conduct mandatory AML and sanctions training for employees.

• Provide role-specific guidance for compliance officers, front-line staff, and management.

• Leverage UAE FIU’s free training resources.

Get Training from Future Compliance

Step 3: Essential Elements of an Effective Sanctions Screening Program

Regulatory Requirements & Compliance

As per Article 21.2 of Cabinet Decision 74, Licensed Financial Institutions (LFIs) are required to:

• Perform regular searches against applicable sanctions lists for customers, transactions, beneficial owners, and related entities.

• Conduct continuous screening before executing transactions or establishing new business relationships.

• Ensure sanctions screening systems are only as effective as the quality of customer and transaction data used.

Sanctions Screening Guidelines – UAE Central Bank

Key Components of a Strong Sanctions Screening Framework

1.A well-calibrated risk-based approach: LFIs must review and enhance screening frameworks regularly, especially after significant regulatory or business changes.

2.Robust training & risk awareness: Employees must be trained in sanctions screening policies, procedures, and financial crime risks.

3. Integration into a wider compliance strategy: Screening should be closely linked with AML and KYC measures to ensure data accuracy.

4. Active oversight & governance: Senior management and board members should actively monitor and enhancescreening systems, addressing inefficiencies and staff-related issues promptly.

5.Quality assurance: LFIs should implement regular audits and validation processes to ensure screening accuracy and compliance with regulatory requirements.

Step 4: Ensure Ongoing Compliance & Audits

• Perform Regular Sanctions Audits – Conduct internal reviews of your sanctions screening processes.
• Monitor Transactions for Red Flags – Identify suspicious transactions linked to high-risk jurisdictions or entities.
• Enhance Due Diligence on High-Risk Customers – Apply Enhanced Due Diligence (EDD) for politically exposed persons (PEPs) and high-risk sectors.
• Use AI & Automation for Screening – Invest in AI-powered real-time transaction monitoring systems.

Penalties for Non-Compliance

Failure to comply with sanctions screening obligations can result in:

• Fines from AED 50,000 to AED 50 million

• Freezing or suspension of business operations

• Criminal liability for executives & compliance officers

• Reputational damage & banking restrictions

UAE sanctions enforcement guidelines

Step 5: Register with EOCN & Subscribe to Sanctions Lists

Why Register with EOCN?

Registering with the Executive Office for Control & Non-Proliferation (EOCN) ensures businesses receive real-time updates on sanctioned individuals and entities, helping them stay compliant with UAE regulations.

How to Subscribe to the UAE Sanctions Lists:

1️⃣ Access the Executive Office’s Website
https://www.uaeiec.gov.ae/en-us/un-page

2️⃣ Navigate to “Sanctions List” in Quick Links

3️⃣ Click on Subscribe

4️⃣ Fill Out the Subscription Form

5️⃣ Submit & Receive Confirmation Email
Subscribers receive email notifications whenever updates occur on the UAE Local Terrorist List or the UN Consolidated List.

📧 For More Information, Contact: IEC@UAEIEC.GOV.AE