Sanctions screening for company and trust service providers in the UAE

Under Article 3 of Cabinet Resolution No. 134 of 2025, company and trust service providers are DNFBPs when, for customers, they:

• act as formation agent for legal persons;
• act, or arrange for someone to act, as a director, secretary, partner or nominee shareholder;
• provide a registered office, business, correspondence or administrative address; or
• act, or arrange for someone to act, as trustee of an express trust or similar arrangement.

The Ministry of Economy and Tourism's 2026 guidance for this sector says providers must screen customers, beneficial owners and other related parties, freeze assets when required, and report matches and actions taken. In practice that means:

• the customer, whether an individual or a company;
• every ultimate beneficial owner, looking through layers of ownership;
• directors, nominees, trustees and anyone with power of attorney; and
• existing clients again whenever the sanctions lists are updated.

Freezing measures apply not only to designated persons but also to entities they own or control, directly or indirectly, and to anyone acting on their behalf or at their direction. For a provider forming or administering companies, a structure owned or controlled through a chain by a designated person is itself caught, so beneficial ownership screening is where the real risk sits.

For a confirmed match, stop the service immediately, do not complete the formation or continue administering the structure, and file a Confirmed Name Match Report (CNMR) in goAML within five business days. For a partial match you cannot resolve, suspend or reject and file a Partial Name Match Report (PNMR). See how to file a CNMR or PNMR, and our full guide to screening against the UAE Local Terrorist List and UN Consolidated List.