1. Does the UAE have a sanctions regime in place?

Yes, although the UAE does not widely publicize what sanctions are in force (other than the designated lists of individuals and entities described below). According to the UAE authorities, EU, UN, and US sanctions will be enforced on an ad hoc basis upon the issuance of internal directives.

2. Does the UAE implement UN sanctions?

Yes, but these are implemented on an ad hoc basis. In respect of UNSC resolutions relating to the prevention and suppression of terrorism, terrorist financing and proliferation of weapons of mass destruction in particular, UAE law prohibits legal and natural persons from making funds (directly or indirectly) available for the benefit of designated individuals and entities (and those owned or controlled) on the UN sanctions list, unless permitted by the Committee of Goods & Materials subject to Import and Export Control or certain exemptions. There are also asset freezing obligations.

3. Does the UAE implement an autonomous sanctions regime?

The UAE maintains a local list of designated terrorist individuals, entities and groups which are identified as posing a threat to the country and / or based on a request from another country. The UAE may also implement federal laws imposing sanctions against countries on an ad hoc basis based on foreign policy.

4. What is the nature of the sanctions regime in the UAE?

The UAE implements sanctions imposed by the UN on an ad hoc basis, upon the issuance of internal directives. Specifically, the Ministry of Interior has confirmed implementation of UN sanctions concerning Somalia, Iran and North Korea.

The UAE has also reported to UN sanctions committees with regard to its implementation of UN sanctions targeting Libya, Sudan, Iran and North Korea, for instance by outlining the practical measures in place in the UAE for implementation of the relevant UNSC or by stating more generally its commitment to implementing the relevant UNSC resolutions.

US and EU sanctions may also be adopted on an ad hoc basis. This may occur further to normal requests transmitted to the customs authorities or other relevant law enforcement authorities and upon examination of the circumstances and justifications advanced in support of the request.

Further, the UAE may also enforce sanctions imposed by inter-governmental organisations of which it is a member such as the Arab League or the Gulf Cooperation Council (GCC) by issuing circulars internally among UAE authorities and / or updating its national sanctions list of designated individuals and entities.

5. Does the UAE maintain a list of sanctioned individuals and entities?

As stated above, the UAE maintains a local list of terrorist individuals, entities and groups and also circulates the UN consolidated list to relevant Government authorities, regulators and regulated firms. Both lists are published on the website of the Committee of Goods & Materials subject to Import and Export Control.

6. Are there any other lists related to sanctions?


7. Does the UAE have a licensing or authorization system in place?

No, although there are procedures to seek authorisation from the Committee of Goods & Materials subject to Import and Export Control to permit certain transactions concerning individuals or entities designated on the UN sanctions list.

8. What are the consequences for a breach of sanctions in the UAE?

Information regarding the UAE sanctions regime is not readily available. However, given that a sanctions regime is in place, the provisions relating to the general import and export of prohibited goods will be applied to breaches of sanctions, to the extent that they involve similar trade measures. With regard to the breach of export control rules, the potential penalties for export of export-controlled items without a license comprise the following: at least one year’s imprisonment a fine of at least Emirati Dirham 50,000 (approximately USD 13,610) but no more than Emirati Dirham 500,000 (approximately USD 136,100).

The fine is doubled in instances of repeated offences and the goods may also be confiscated. In addition, where the action in question also constitutes a particular crime, for example the funding of a terrorist organization, criminal penalties may also be imposed.

The competent authorities in the UAE may impose penalties for failures to comply with the legislative requirements in respect of the UN list of designated persons and entities. This includes imprisonment or a fine of no less than Emirati Dirham 50,000 (approximately USD 13,610) and no more than Emirati Dirham 5,000,000 (approximately USD 1,361,296). The supervising authorities of regulated firms may also apply administrative sanctions for failure to comply with obligations in respect of sanctions.

9. Who are the relevant regulators in the UAE and what are their contact details?

Ministry of Interior and Federal Customs Authority Federal Customs Authority Ministry of Finance Building 2nd Floor, Fatima Bint Mubarak St Abu Dhabi, United Arab Emirates E:

Committee of Goods & Materials subject to Import and Export Control BurDubai- Umm Hurair1- Khalid Bin Al walid st – Consulates Area in the Ministry of Foreign Affairs and International Cooperation/ Dubai Office

T: (+971) 4 4040040 F: (+971) 4 3574499 E:

Abu Dhabi T: (+971) 2 697 9700 F: (+971) 2 673 5201 P.O. Box: 35000

Dubai T: (+971) 4 311 9900 F: (+971) 4 393 0446

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Nasser Ali Khasawneh


Shibani Kapur

Senior Associate

Eversheds Sutherland Emaar Square Building 6 Level 8,

Unit 803,

Burj Khalifa

PO Box 74980,

United Arab Emirates

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