UAE sanctions screening duty for traders (Cabinet Resolution 74/2020)
By the Vanguard Verify desk · Published 2026-11-04 · Updated 2026-11-04
Short answer: under UAE Cabinet Resolution No. 74 of 2020, targeted financial sanctions (TFS) apply to every natural and legal person in the UAE — traders included. You must screen counterparties against the UAE Local Terrorist List and the UN Security Council Consolidated List, freeze any funds of a listed person without delay (immediately, and in any case within 24 hours), and never make funds or services available to them. Regulated firms (financial institutions, DNFBPs such as precious-metals dealers, and VASPs) must also subscribe to the Executive Office alerts and report matches through goAML within five business days.
What Cabinet Resolution 74 of 2020 is
Cabinet Resolution No. 74 of 2020 regulates the UAE terrorist lists and the implementation of UN Security Council resolutions on terrorism, terrorist financing and the proliferation of weapons of mass destruction. The Executive Office for Control & Non-Proliferation (the Executive Office) issued guidance on how to apply it. That guidance states TFS "must be implemented by any Person (both natural and legal entities)" — so it is not only a bank problem. A commodity trading company in Dubai, a free-zone broker, or a gold dealer all carry the duty.
The two lists you screen against
| List | Issued by | Where to get it |
|---|---|---|
| UAE Local Terrorist List | UAE Cabinet | Executive Office website (uaeiec.gov.ae) |
| UN Security Council Consolidated List | UN Security Council | UN website; linked from the Executive Office |
Many traders also screen against other lists (for example US OFAC or EU lists) because their banks or buyers demand it. That is good practice, but the UAE legal duty under Resolution 74 is built on the two lists above.
Six steps for a trader
- Subscribe to list updates. FIs, DNFBPs and VASPs are required to subscribe to the Executive Office notification system so they get automatic email alerts when the lists change. Any trading company can follow the same practice.
- Screen before you deal. Check the counterparty company, its directors, shareholders and beneficial owners, and anyone acting for it, before you sign or move money. The Ministry of Economy says to search your customer database before any operation or serious business relationship.
- Re-screen when lists change. A clean result last month does not cover a designation made this week. Re-run your existing customers and open deals against every update.
- Freeze on a match. On a confirmed match, freeze funds and assets without delay and without telling the listed person — the guidance defines this as immediately, and in any case within 24 hours. On a potential (partial) match, suspend the transaction until you get instructions.
- Report. Supervised firms report through the UAE FIU's goAML platform: a Fund Freeze Report (FFR) for a confirmed match or a Partial Name Match Report (PNMR) for a potential match, within five business days. Do not tip off the customer.
- Keep records. Save what you screened, when, against which list version, and what you decided. Supervisors check this.
Red flags that should stop the deal
- The seller refuses to name the beneficial owner or the real refinery/producer.
- The company was formed recently and the "mandate" cannot show who controls it. Check the trade licence first — see how to check a UAE company.
- Payment is routed to a third party or a country with no link to the goods.
- Names are spelled several different ways across the documents.
- Vessel, origin or ports cannot be confirmed independently (see how to check a vessel IMO number).
- Pressure to skip screening "because the bank already did it".
What happens if you get it wrong
The Executive Office guidance lists criminal penalties for breaching TFS duties, including imprisonment and fines from AED 50,000 up to AED 5,000,000, and supervisors can impose administrative fines per violation on regulated firms. Banks will also close accounts that cannot show screening controls.
What a company check does — and does not — do
A company check confirms the counterparty exists, who is behind it, and whether its documents line up. It helps you collect the names you must screen. It does not replace your own legal duty to screen, freeze and report under UAE law. This page is general information, not legal advice; ask a UAE compliance adviser about your specific licence.
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FAQ
Does Cabinet Resolution 74 of 2020 apply to commodity traders?
Yes. The Executive Office guidance says targeted financial sanctions must be implemented by any natural or legal person in the UAE, not only banks.
How fast must funds be frozen?
Without delay: immediately, and in any case within 24 hours of identifying a confirmed match, without prior notice to the listed person.
How are matches reported?
Supervised firms report through the UAE FIU goAML platform: a Fund Freeze Report for a confirmed match or a Partial Name Match Report for a potential match, within five business days.
Which lists must be screened?
The UAE Local Terrorist List and the UN Security Council Consolidated List.
Vanguard Verify is run by Vanguard Trade Capital Goods Wholesalers DWC-LLC, Dubai South, Licence 14282. This answer is general information, not legal or financial advice.