Local Terrorist List

The UAE Cabinet issues the Local Terrorist List on the proposal of the Supreme Council for National Security. The Executive Office for Control and Non-Proliferation (EOCN) publishes the list on its website and circulates updates through its Notification Alert System.

The current Local Terrorist List is available on the EOCN website (in PDF and Excel formats) and via the Notification Alert System. Reporting Entities must register with the NAS to receive automated email updates whenever the list changes.

The UN Consolidated List is compiled by UNSC Sanctions Committees under Chapter VII UNSCRs (such as 1267, 1988 and 1718) and applies globally. The UAE Local Terrorist List is a domestic list issued by the UAE Cabinet under UNSCR 1373 and applies within the UAE framework. Reporting Entities must screen against both.

Screening must be ongoing and risk-based. This includes daily list checks, onboarding screening, transaction screening, periodic KYC review, and immediate re-screening whenever the list is updated. Screening procedures must continue on weekends and public holidays where access to funds remains possible.

On a confirmed match, the Reporting Entity must freeze funds and prohibit the provision of services without delay (within 24 hours of designation), preserve the freeze rather than closing the account, notify the Supervisory Authority and the Executive Office within two business days, and file a CNMR through goAML within five business days. For a partial match, the response depends on whether it concerns an existing customer, potential customer or transaction in progress; in each case, the Reporting Entity should follow the current EOCN PNMR workflow and submit a PNMR through goAML within five business days of the relevant suspension or rejection event.

Yes. The Supreme Council for National Security conducts periodic reviews of the Local Terrorist List and, if it considers that the designation criteria are no longer met, proposes de-listing. De-listing takes effect only once the UAE Cabinet approves the proposal. Listed persons and affected third parties may also submit grievances to the Executive Office.

A listed person or their legal representative may submit a written application to the Executive Office for permission to use part of the frozen funds for necessary or basic expenses (food, rent, mortgage, medicine, medical treatment, insurance, education, legal and judicial fees, and public utility fees), subject to Ministry of Justice approval and Supreme Council coordination.

Yes. Virtual Asset Service Providers are Reporting Entities under Cabinet Decision No. 74 of 2020 and the 2025 AML/CFT framework, and must screen against the UAE Local Terrorist List and the UN Consolidated List, freeze without delay and file CNMRs or PNMRs through goAML.

Under Article 33 of Federal Decree-Law No. 10 of 2025, any person who violates the instructions of the Executive Office or other Competent Authority on Targeted Financial Sanctions is liable to imprisonment and a fine of not less than AED 20,000, or either penalty. Article 17 of the same Decree-Law empowers Supervisory Authorities to impose administrative penalties ranging from warnings to fines of AED 10,000 to AED 5 million per violation, prohibition from the sector, restriction of powers of responsible persons, and cancellation of the business licence. Legal persons convicted of core AML/CFT/CPF offences face fines of up to AED 100 million or the value of the criminal property, whichever is greater. Federal Law No. 7 of 2014 (as amended by Federal Law No. 4 of 2024) applies separately to underlying terrorist offences.

Yes. The UAE TFS framework expressly protects persons who act in good faith. Any person who, in good faith, freezes funds or refuses to provide financial services to designated individuals, entities or groups in compliance with Cabinet Decision No. 74 of 2020 is exempt from damages or claims, including criminal, civil and administrative liability. This protection applies even where the freezing measure later turns out to have involved a false positive. Where a similarly-named person is adversely affected, that person may apply to the Executive Office for de-freezing.

Yes, in limited circumstances. The EOCN confirms that frozen accounts may be credited with interest, profits or other earnings due on the account, and with payments due under contracts, agreements or obligations concluded or arising before the date on which the individual or legal entity was designated. Any such additions must themselves be immediately frozen, and the relevant Supervisory Authority and the Executive Office must be notified. This allows institutions to comply with the freezing regime without breaching pre-existing contractual obligations to third parties.

No. CBUAE guidance is clear that external screening tools are useful but should not be viewed as an absolute guarantee of compliance. Reporting Entities must undertake due diligence on vendors and ensure that vendor lists fully reflect the current UAE Local Terrorist List and UN Consolidated List as published by the EOCN and the UNSC. Registration on the EOCN Notification Alert System (NAS) is required to receive timely updates directly from the source, and the official EOCN and UNSC publications take precedence over any vendor list in the event of a discrepancy.