Screening vendors against the UAE sanctions lists

Sanctions screening is usually thought of as a customer problem. In the UAE the duty is wider. Cabinet Decision 74 of 2020, which governs targeted financial sanctions and is still the instrument the CBUAE and the FSRA cite, asks firms to screen customers, counterparties, beneficial owners and related persons. Vendors are counterparties.

Which lists, and how often

Two lists matter most: the UAE Local Terrorist List and the UN Security Council Consolidated List. The decision expects firms to subscribe to alerts from the Executive Office for Control and Non-Proliferation (EOCN) and to re-screen immediately after each list update (Art. 21). Periodic batch screening, once a month or once a quarter, does not meet that standard.

What happens on a match

• Freeze without delay, which means within 24 hours of the listing decision, and without prior notice to the listed person (Art. 15).
• Provide no funds or services without EOCN permission. For a vendor, that can mean stopping a scheduled payment.
• Report through goAML: a Fund Freeze Report for a confirmed match, or a Partial Name Match Report for a potential one. CBUAE and FSRA guidance from 2025 gives 5 business days, and the suspension stays in place until instructed.

Screen the people behind the vendor, not only the company name.

Owners and directors count

A vendor's legal name rarely appears on a list; its owners might. Cabinet Resolution 109 of 2023 defines a beneficial owner as a natural person who owns or controls 25% or more of the shares or votes, directly or indirectly. Collect owners and directors at onboarding and screen each of them. Under the new AML law, Federal Decree-Law 10 of 2025, knowingly giving false beneficial-ownership information is a criminal offence (according to law-firm summaries).

Keep the evidence

Cabinet Decision 134 of 2025, the AML executive regulations in force since 14 December 2025, keeps a minimum five-year record-retention rule. Keep every screening result, each partial match, who cleared it and why. If you outsource the screening tool, the FSRA treats it as outsourcing that needs periodic assurance (AML Rulebook 9.3.1).

Where NexaPair stands

Sanctions and PEP screening through OpenSanctions is live and re-runs while a vendor is active. Screening against the UAE Local Terrorist List and the UN list is live too: vendors, directors and owners are re-screened after every list update, and each confirmed or partial match opens a case with the 24-hour freeze and five-business-day report clocks. You connect the list feed you are licensed to use. Sanctions matches are never auto-cleared: a person always decides.