Who must do sanctions screening in the UAE?

Article 21 of Cabinet Decision No. 74 of 2020 places targeted financial sanctions obligations on financial institutions and designated non-financial businesses and professions (DNFBPs). The EOCN guidance applies the same obligations to virtual asset service providers (VASPs). Together, the EOCN calls them reporting entities. Who falls into each group is defined in Cabinet Resolution No. 134 of 2025.

Under Article 2 of Cabinet Resolution No. 134 of 2025, a financial institution is anyone who, as a commercial activity, carries out financial activities for customers, including:

• taking deposits, and lending, including consumer and mortgage loans;
• financial leasing, other than for consumer products;
• money or value transfer services, and money or currency exchange;
• issuing and managing means of payment such as cards, cheques and electronic money;
• guarantees, trading in financial instruments, securities issuance, and fund and portfolio management;
• safekeeping and administering cash or securities for others; and
• life insurance and other investment-related insurance, including through agents and brokers.

Article 3 of Cabinet Resolution No. 134 of 2025 lists the DNFBPs, several with transaction thresholds:

• Real estate brokers and agents, when carrying out transactions for customers involving the purchase or sale of real estate.
• Dealers in precious metals and stones, for any single cash transaction, or linked transactions, of AED 55,000 or more.
• Lawyers, notaries, other independent legal professionals and independent accountants, when preparing or carrying out transactions for customers involving buying or selling real estate, managing customer funds or accounts, organising contributions for companies, or creating, operating or buying and selling companies and legal arrangements.
• Company and trust service providers, when acting as a formation agent, as or arranging a director, secretary or nominee shareholder, providing a registered office or address, or acting as a trustee.
• Commercial gaming operators, for financial transactions, or linked transactions, of AED 11,000 or more.

The supervisory authority can add other businesses or professions by resolution.

Anyone who, as a commercial activity, carries out virtual asset activities for or on behalf of another person is a VASP under the 2025 framework, and the EOCN guidance applies the full targeted financial sanctions steps to them. For a VASP, freezing can mean blocking trading and transfers or restricting access to accounts.

In short, every reporting entity must:

• register for EOCN list update notifications;
• screen customers, prospects, former customers from the last five years, beneficial owners, transaction parties and people acting for customers;
• freeze without delay (within 24 hours) and stop services on a confirmed match;
• report through goAML with a CNMR or PNMR within five business days; and
• keep screening records, including false positives, for at least five years.

The full process is in our guide to screening against the UAE Local Terrorist List and UN Consolidated List.

Free zones. Businesses in financial free zones such as ADGM and the DIFC have their own regulators and rulebooks, but federal targeted financial sanctions still apply. ADGM's regulator, for example, reminded firms in July 2025 to register on goAML, subscribe to EOCN notifications and screen in line with Article 21 of Cabinet Decision No. 74 of 2020.

Using a consultant or software. Many businesses rely on an AML service provider or a screening platform. That can make the work faster and more consistent, but the legal obligation stays with the regulated business itself.

Penalties. Article 29 of Federal Decree Law No. 10 of 2025 makes it an offence, punishable by imprisonment, a fine of at least AED 50,000, or both, to violate an order of a competent authority on freezing, and to warn a person or disclose that a transaction is under review as suspicious.

RiskLens360 is built for every group above, and offers packages for AML service providers who run screening for many client businesses. Request a demo.