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Sanctions screening in the UAE
We screen your customers, suppliers, shareholders and beneficial owners against the sanctions lists that apply in the UAE, then give you a dated report for your compliance file.
- Every list fetched live on the day of screening
- Every owner, director and signatory checked
- A dated report with the reasoning for each flag
What to do, and by when
What has happened?
Screen the business and every person behind it at onboarding. That means each shareholder, director, manager, authorised signatory and beneficial owner, plus trading names.
- When
- At onboarding
- Lists
- UAE Local Terrorist List and UN Consolidated List
- Keep
- Dated report and search evidence for five years
This is general guidance and is not legal advice; reports are filed by your own authorised compliance officer.
Sanctions screening, in brief.
Sanctions screening is the check of a person or company against official sanctions and terrorist lists before and during a business relationship. In the UAE, two lists are mandatory by law: the UAE Local Terrorist List and the UN Security Council Consolidated List.
UAE businesses with anti-money laundering reporting duties need it for customers, counterparties and owners. My Eloah Business Hub screens your file against lists fetched live on the day and produces a dated report for your compliance officer.
- Mandatory lists
- UAE Local Terrorist List and UN Consolidated List
- Freeze deadline
- Within 24 hours of a confirmed match
- Owner threshold
- Beneficial owners at 25% or more
- Records
- Kept for five years
Which lists apply in the UAE.
Two lists carry legal force in the UAE. Others have no force in UAE law, yet banks screen them, so they matter in practice.
| List | Status in the UAE | Why it matters |
|---|---|---|
| UAE Local Terrorist List | Mandatory under UAE law | A confirmed match means a freeze within 24 hours |
| UN Security Council Consolidated List | Mandatory under UAE law | A confirmed match means a freeze within 24 hours |
| OFAC SDN List (United States) | Not UAE law | Banks screen it; a hit can end an account application |
| OFAC Non-SDN Consolidated List | Not UAE law | Banks screen it; a hit can end an account application |
| UK Sanctions List | Not UAE law | The single UK source since the OFSI Consolidated List closed on 28 January 2026 |
| EU Consolidated List | Not UAE law | Banks screen it; a hit can end an account application |
| Sector and country lists | By risk and sector | For example the BIS Entity List for dual-use and re-export exposure, and World Bank Debarred Firms for contractors and public tenders |
Updates to the two mandatory lists are sent through the Notification Alert System (NAS) of the Executive Office for Control and Non-Proliferation. Subscribing is itself a legal obligation.
When you must screen.
Screening is a point-in-time check, so it has to be repeated when something changes.
Before the relationship starts
Screen the company, its trading names and every person in the structure when you take on a customer or counterparty.
When the file changes
Screen again on any change in ownership, signatory or beneficial owner, and at periodic reviews set by the risk rating.
When the lists change
Screen again on any NAS alert naming a new designation, and before any significant transaction.
What to do, and by when.
The duty and the deadline depend on which list the match is on and how certain it is.
| Finding | What you must do | Deadline |
|---|---|---|
| Confirmed match to the UAE Local Terrorist List or UN Consolidated List | Freeze all funds. Do not notify the customer. File a Funds Freeze Report (FFR) | Freeze within 24 hours. FFR within 5 business days of freezing |
| Potential match to either list | File a Partial Name Match Report (PNMR) | Without delay |
| Match to OFAC, UK or EU lists only | No UAE freeze duty. Flag it to the compliance officer | No set deadline |
| Transaction involving a country on the National Committee's high-risk list | File an HRC or HRCA report. Execute only if the Financial Intelligence Unit has not objected | Before executing. Wait three working days after reporting |
| Suspicion of money laundering or terrorist financing, with or without a list hit | File a Suspicious Transaction Report (STR) or Suspicious Activity Report (SAR) | Without delay |
Filing is the act of your firm's authorised compliance officer. We prepare the drafts and the evidence; we do not file on our own authority.
Where businesses get caught out.
Most failures come from gaps in the process, and each one is avoidable.
Telling the customer
Telling a person they matched or are being reported is a crime. The penalty is imprisonment plus a fine of not less than AED 50,000.
Screening an old copy
The lists change continuously. A saved copy can return a clean result on a newly designated person, which is the worst record a compliance file can hold.
Skipping a beneficial owner
Screening the company and missing an owner behind it is the classic failure. Corporate shareholders must be traced up to natural persons.
Not subscribing to NAS
Subscribing to the Notification Alert System is a legal obligation. Failing to subscribe is a breach even if you never miss a name.
What to keep for five years.
A supervisor asks for evidence that you screened, so the file has to show the work.
Seven steps to a screening report.
This is how My Eloah Business Hub handles a screening file from documents to compliance record.
Start on WhatsApp →Share the documents
Send the passports, Emirates IDs, trade licence, memorandum of association and beneficial owner declaration for the file.
We list every party
We extract each person and company in the structure, including owners at 25% or more and anyone with control by other means.
We fetch the lists live
Each list is retrieved on the day, and the report records the version or retrieval date.
We match the names
We search spelling and transliteration variants, the passport machine-readable name, and trading names with and without the legal suffix.
We test each flag
We compare date of birth, passport or ID number, nationality and place of birth to separate true matches from false ones.
You receive the report
The report shows parties screened, lists used, results by party, how each flag was resolved, country risk and a recommended action.
Your officer decides and files
Your compliance officer reviews and signs the report, and files any report that is due using the drafts we prepare.
Sanctions screening, answered.
Ask anything else on WhatsApp and we will answer for your company.
Which sanctions lists are mandatory in the UAE?
Two lists are mandatory under UAE law: the UAE Local Terrorist List and the UN Security Council Consolidated List. Lists such as OFAC, the UK Sanctions List and the EU Consolidated List are not UAE law, but banks screen them.
How quickly must funds be frozen after a confirmed match?
Within 24 hours. Cabinet Decision 74 of 2020 requires a freeze within 24 hours of a designation, and a Funds Freeze Report (FFR) is due within 5 business days of freezing.
What should I do if a name is only a possible match?
Treat it as a potential match and pass it to your compliance officer, who files a Partial Name Match Report (PNMR) without delay. Do not clear it unless a hard detail such as date of birth or passport number positively excludes the person.
Can I tell a customer that they matched a sanctions list?
No. Telling a customer they matched or are being reported is the offence of tipping off, punished by imprisonment plus a fine of not less than AED 50,000.
Who in a company needs to be screened?
Every natural and legal person in the structure. That covers the applicant, each shareholder, director, manager and authorised signatory, each beneficial owner at 25% or more, the company and its trading names, parent and subsidiary companies, and significant counterparties.
How long must sanctions screening records be kept?
Five years. Keep the signed report, dated search evidence, the version or retrieval date of each list, and the reasoning for every cleared potential match.
Does a link to a FATF grey list country mean enhanced due diligence?
No, not on Financial Action Task Force (FATF) grounds alone. FATF asks for a risk-based approach to grey list countries, and in the UAE the list with legal effect is the high-risk list published by the National Committee for Combating Money Laundering and the Financing of Terrorism and Illegal Organisations.
Does your screening cover politically exposed persons and adverse media?
No. Our report notes politically exposed person (PEP) indicators found in the documents, but it is not a PEP database or adverse media check, and it is a point-in-time screen. Where the risk calls for it, we recommend a licensed screening provider.
Screen the file before you sign.
Send us the documents on WhatsApp and we will tell you what a screening of that file involves and what it costs.