UAE sanctions screening checklist for 2026

• Register on the EOCN Notification Alert System to receive list updates by email.
• Register on goAML if your category requires it; businesses that are not required to register report measures to the EOCN by email.
• Write internal policies for screening, freezing and reporting, including weekends and public holidays.
• Add a policy that stops staff telling anyone that a freeze or other measure will be applied.
• Map every system that holds customer or transaction data to your screening process.

• Existing customers and potential customers.
• Former customers from the last five years.
• Parties to transactions, such as buyers, sellers and agents.
• Beneficial owners, both individuals and companies.
• Directors, and anyone acting for the customer under a power of attorney.

Beneficial owner rules are covered in UBO requirements in the UAE, and whether your business is in scope in who must do sanctions screening.

• Immediately whenever the UAE Local Terrorist List or the UN Consolidated List is updated.
• Before onboarding a new customer.
• At periodic reviews, and when a customer's nature or ownership changes materially.
• Before processing a transaction for a counterparty.

Full detail: how to screen against the UAE Local Terrorist List and UN Consolidated List.

• Compare key identifiers first: name, date of birth, nationality, ID or passport number, address.
• Classify the result as a confirmed match, partial match, false positive or negative.
• Document the reasoning for false positives, even though no report is filed.

See handling confirmed matches, partial matches and false positives.

• Confirmed match: freeze without delay, within 24 hours, and without prior notice, or reject a prospect.
• Stop making any funds, assets or services available.
• Partial match on an existing customer: suspend until the EOCN responds.
• Check companies owned or controlled by the designated person, and anyone acting for them.

For companies linked to a designated person, see owned or controlled: when to freeze.

• File a CNMR for a confirmed match, or a PNMR for a partial match, in goAML within five business days.
• Attach the supporting documents.
• File a separate suspicious transaction report where there is also suspicion of a crime.

See CNMR and PNMR in goAML.

• Keep every screening result, including false positives, for at least five years.
• Record who reviewed each hit, what they decided and why.
• Never tell the customer or a third party about a freeze, a report or a review.

The hardest items to keep up by hand are rescreening every customer on every list update and keeping an audit trail of every decision. RiskLens360 screens instantly, in bulk and periodically, and records each case decision. Compare screening software or request a demo.