UNSC Sanctions
Last Updated: 04/21/2026
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United Nations Security Council Overview
- The United Nations Security Council (UNSC) adopts legally binding resolutions, including targeted financial sanctions, to maintain international peace and security.
- In the UAE, UNSC sanctions are operationalised primarily through Cabinet Decision No. 74 of 2020, which remains the core TFS instrument.
- The wider AML/CFT/CPF framework is set by Federal Decree-Law No. 10 of 2025 and Cabinet Resolution No. 134 of 2025.
- Financial institutions, DNFBPs and VASPs (Reporting Entities) must register with the Executive Office, screen continuously, freeze without delay, and report matches through goAML.
- Non-compliance can lead to fines of up to AED 5 million under Cabinet Decision No. 74 of 2020, imprisonment, and heightened penalties under the 2025 AML/CFT Law.
What are UNSC Sanctions?
The United Nations Security Council is one of the six principal organs of the United Nations, established under the UN Charter of 1945. It holds primary responsibility for the maintenance of international peace and security, and is the only UN body with the authority to issue resolutions that are legally binding on all UN member states.
The UNSC is composed of fifteen members: five permanent members with veto power and ten non-permanent members elected by the General Assembly for staggered two-year terms. Under Chapter VII of the UN Charter, the Council may impose sanctions, including asset freezes, travel bans, arms embargoes and sectoral restrictions, to respond to threats to international peace.
The Five Permanent Members (P5)
| Permanent Member | Note |
|---|---|
| China | The People’s Republic of China replaced the Republic of China (Taiwan) in the UNSC seat in 1971. |
| France | Founding permanent member since 1945. |
| Russian Federation | Succeeded the Soviet Union in the UNSC seat in 1991 following the dissolution of the USSR. |
| United Kingdom | Founding permanent member since 1945. |
| United States | Founding permanent member since 1945. |
How UNSC Sanctions Apply in the UAE
UNSC sanctions regimes target specific individuals, entities and jurisdictions identified as threats to international peace. The principal measures include:
- Asset freezes: Prevent access to, transfer or use of funds, economic resources or other assets owned or controlled by designated persons or entities.
- Travel bans: Restrict the movement of designated individuals across the territory of member states.
- Arms embargoes: Prohibit the sale, supply, transfer or provision of weapons, related goods and associated training or services.
- Sectoral restrictions: Include bans on trade in specific commodities or sectors, used for example against the DPRK.
As a UN member state, the UAE implements UNSC sanctions in full. In practice, sanctions compliance is operationalised through daily screening, freezing and reporting duties imposed on regulated entities.
Major UNSC Sanctions Regimes Producing the UN Consolidated List
| UNSCR | Regime | Focus |
|---|---|---|
| 1267 / 1989 / 2253 | ISIL (Da’esh) and Al-Qaida Sanctions Committee | Counter-terrorism: asset freezes, travel bans and arms embargoes against listed persons and entities. |
| 1988 (2011) | Taliban Sanctions Committee | Asset freezes, travel bans and arms embargoes linked to the security and stability of Afghanistan. |
| 1718 (2006) | DPRK Sanctions Committee | Targeted financial sanctions, arms embargo and sectoral restrictions on the Democratic People’s Republic of Korea. |
Other active UNSC sanctions committees (for example, committees on Libya, Somalia and Al-Shabaab, Sudan, South Sudan, Yemen, Haiti, the Democratic Republic of the Congo, Guinea-Bissau, and Iraq) also contribute designations to the UN Consolidated List. The list of active committees evolves, so Reporting Entities should rely on the UNSC’s official Consolidated List as the authoritative source.
Related UNSC Measures (Not Designation Regimes)
UNSCR 1373 (2001) is not a UNSC designation regime. It requires each UN member state to criminalise terrorist financing and to develop procedures to identify and designate individuals and entities suspected of terrorist acts domestically. In the UAE, UNSCR 1373 underpins the UAE Local Terrorist List prepared by the Supreme Council for National Security and approved by the UAE Cabinet.
UNSCR 1540 (2004) is a non-proliferation resolution that obliges states to prevent non-state actors from acquiring weapons of mass destruction. The 1540 Committee is not a sanctions committee and does not designate individuals. 1540 compliance is relevant to the UAE’s broader counter-proliferation financing (CPF) framework.
UAE Legal Framework for Targeted Financial Sanctions
The UAE gives effect to UNSC sanctions obligations through a layered legal framework.
- Federal Decree-Law No. 10 of 2025 on Combating Money Laundering, the Financing of Terrorism and the Financing of Proliferation, effective 14 October 2025, repealed and replaced Federal Decree-Law No. 20 of 2018 and introduced proliferation financing as a standalone offence.
- Cabinet Resolution No. 134 of 2025 provides the Executive Regulations to Federal Decree-Law No. 10 of 2025, effective 14 December 2025. It replaced Cabinet Decision No. 10 of 2019.
- Cabinet Decision No. 74 of 2020 on the Terrorism Lists Regulation and the Implementation of UN Security Council Resolutions remains the core UAE TFS implementation instrument, covering the UN Consolidated List and the UAE Local Terrorist List.
- Guidance on Targeted Financial Sanctions, issued by the Executive Office for Control and Non-Proliferation (EOCN), was updated in July 2025. It sets out the operational expectations for screening, freezing and reporting by Reporting Entities.
The scope of Cabinet Decision No. 74 of 2020 covers the UN Consolidated List and the UAE Local Terrorist List. Other unilateral and multilateral sanctions lists (for example, OFAC, UKHMT or EU lists) fall outside the scope of this Decision but may still create risk requiring escalation through suspicious transaction or activity reporting.
UNSC Sanctions UAE Requirements at a Glance
In practical terms, UNSC sanctions UAE requirements translate into five operational duties for Reporting Entities:
- Register with the EOCN Notification Alert System and on the goAML portal.
- Screen customers, potential customers, beneficial owners and transactions against the UN Consolidated List and the UAE Local Terrorist List on an ongoing and risk-based basis.
- Freeze funds and prohibit the provision of funds or services without delay (within 24 hours of designation) on any confirmed match.
- Notify the relevant Supervisory Authority and the Executive Office within two business days of any freezing measure or attempted transaction.
- File a CNMR or PNMR through goAML within five business days, and consider an STR or SAR where suspicion exists outside the scope of Cabinet Decision 74 of 2020.
UNSC Consolidated List vs UAE Local Terrorist List vs Other Sanctions Lists
UAE Reporting Entities must understand the three categories of sanctions exposure they may encounter.
| Feature | UNSC Consolidated List | UAE Local Terrorist List | Other Sanctions Lists |
|---|---|---|---|
| Issuing Authority | UNSC and its Sanctions Committees | UAE Cabinet (on proposal of the Supreme Council for National Security) | Foreign or regional authorities (e.g. OFAC, UKHMT, EU) |
| Legal Basis | UNSCRs adopted under Chapter VII, UN Charter | UNSCR 1373 (2001) and UAE federal law | Domestic laws of the issuing jurisdiction |
| UAE TFS Obligation | Yes, under Cabinet Decision 74 of 2020 | Yes, under Cabinet Decision 74 of 2020 | Outside scope of Cabinet Decision 74 of 2020 |
| Reporting Mechanism | CNMR or PNMR via goAML | CNMR or PNMR via goAML | Consult Supervisory Authority; consider STR/SAR if suspicion exists |
Key TFS Obligations for FIs, DNFBPs and VASPs
Cabinet Decision No. 74 of 2020 imposes the underlying TFS obligation on all natural and legal persons in the UAE. Article 21 of the Decision sets out the operational obligations that apply specifically to Reporting Entities (FIs, DNFBPs and VASPs).
| Obligation | Requirement |
|---|---|
| 1. Register | Register on the Executive Office website (Notification Alert System) and on goAML to receive automated email notifications of listing, re-listing, updating and de-listing decisions by the UNSC, the relevant Sanctions Committee or the UAE Cabinet, and to enable submission of TFS reports. |
| 2. Screen | Screen customers, potential customers, beneficial owners and transactions against the UN Consolidated List and the UAE Local Terrorist List on an ongoing and risk-based basis. This includes daily list checks, onboarding screening, transaction screening, periodic KYC review, and immediate re-screening upon any update to the lists. Screening procedures must remain active on weekends and public holidays where business activity or access to funds is possible. |
| 3. Freeze without delay | On a confirmed match, freeze all funds and assets owned or controlled, directly or indirectly, by the designated person, and prohibit the provision of funds or services. ‘Without delay’ is defined in Article 1 of Cabinet Decision 74 of 2020 as immediately or in any case within 24 hours of the listing decision being issued. |
| 4. Notify and Report | Reporting Entities must notify the relevant Supervisory Authority and the Executive Office within two business days of taking any freezing measure or identifying an attempted transaction. In addition, Reporting Entities must file a Confirmed Name Match Report (CNMR) or Partial Name Match Report (PNMR) through goAML within five business days, as applicable, and maintain supporting documentation. Reporting Entities should follow the latest EOCN guidance on CNMR, PNMR and STR/SAR workflows, together with any sector-specific directions issued by the Supervisory Authority. |
Reporting Entities must also establish written policies, procedures and internal controls, deliver staff training to prevent tipping-off, and maintain records for inspection by the Supervisory Authority.
Confirmed Match vs Partial Match vs Suspicious Transaction
The July 2025 EOCN Guidance distinguishes three reporting workflows that Reporting Entities must operate in parallel.
| Scenario | Required Action |
|---|---|
| Confirmed Name Match (CNMR) | Match with the UN Consolidated List or UAE Local Terrorist List is confirmed after reviewing identification documents. Freeze without delay, refrain from providing funds, other assets or services, and submit a CNMR through goAML within five business days from identifying the Confirmed Name Match. |
| Partial Name Match (PNMR) | If a Partial Name Match is identified for an existing customer, suspend without delay any transaction, refrain from offering funds, other assets or services, and submit a PNMR through goAML within five business days from the suspension measures. If it is a potential customer or counterparty, seek identification documents first. If they cannot be obtained within a reasonable time of 10 business days, reject the transaction or service and submit a PNMR through goAML within five business days from rejection. |
| STR / SAR | If the match is with a unilateral or multilateral sanctions list, or another suspicious sanctions-evasion related concern outside the UAE Local Terrorist List and UN Consolidated List, do not use CNMR or PNMR. Consult the relevant Supervisory Authority and consider submitting an STR/SAR to the FIU through goAML. |
Ownership, Control and Acting on Behalf of a Designated Person
Freezing obligations extend beyond directly listed persons. The EOCN’s ‘UN page’ makes clear that freezing measures apply to any entity directly or indirectly owned or controlled, wholly or jointly, by a designated individual, entity or group, as well as to any individual or entity acting on behalf of or at the direction of a designated person.
To operationalise this principle, the EOCN TFS Guidance sets out three distinct tests. Reporting Entities should assess all three together rather than relying on a single ownership percentage.
1. Majority Ownership
An entity is treated as owned by a designated person where the designated person holds more than 50 per cent of the proprietary rights of the legal entity, directly or indirectly.
2. Control (including where ownership is below 50 per cent)
Freezing measures also apply where the designated person exercises control, even with a minority shareholding. Indicators of control include the right to appoint or remove a majority of the administrative or management body, controlling the majority of voting rights under a shareholder agreement, control through a power of attorney, or other arrangements giving effective direction over the entity.
3. Acting on Behalf of or at the Direction of a Designated Person
Reporting Entities must apply TFS measures to individuals or entities acting on behalf of, or at the direction of, a designated person. This includes authorised signatories, power-of-attorney holders and representatives acting for a designated person.
A simple percentage threshold is not sufficient on its own. Reporting Entities should assess ownership, control and acting-on-behalf-of indicators together in line with the latest EOCN guidance, and document their analysis to demonstrate a defensible position to supervisors.
Common Sanctions Screening Mistakes
Supervisory Authorities and EOCN outreach have highlighted recurring compliance failures, including:
- Inadequate understanding of business-wide sanctions risk exposure.
- Reliance on outdated or poorly configured screening software, including vendor lists that do not fully reflect the UN Consolidated List or the UAE Local Terrorist List.
- Failure to re-screen existing customers and transactions when sanctions lists are updated.
- Weak oversight of beneficial ownership and control indicators.
- Lack of procedures to ensure screening and freezing continue on weekends and public holidays.
- Confusion between CNMR, PNMR and STR/SAR workflows, leading to late or misdirected reporting.
- Insufficient staff training on the ‘freeze without delay, do not tip off, then report’ protocol.
Penalties for Sanctions Breaches in the UAE
Non-compliance with UNSC sanctions obligations in the UAE can attract administrative, civil and criminal consequences.
- Under Cabinet Decision No. 74 of 2020, non-compliance may result in imprisonment and fines ranging from AED 50,000 to AED 5 million for specified violations.
- Supervisory Authorities may impose additional administrative sanctions, including warnings, restrictions on activities and cancellation of licences.
- Under Federal Decree-Law No. 10 of 2025, legal persons face fines ranging from AED 5 million to AED 100 million for core offences, and regulators may suspend or remove board members and senior executives whose failures contributed to violations.
- Loss of correspondent banking relationships can impede cross-border transactions, especially for financial institutions.
- Reputational damage and reduced access to international markets can outlast any regulatory penalty.
How AML UAE Supports UNSC Sanctions Compliance
AML UAE helps financial institutions, DNFBPs and VASPs design, implement and refine a sanctions compliance programme that is proportionate to their risk profile and aligned with UAE regulatory expectations. Our support covers:
- Sanctions screening framework: Designing name screening, transaction screening and re-screening processes covering the UN Consolidated List, the UAE Local Terrorist List and other applicable lists.
- Customer due diligence integration: Embedding sanctions screening into onboarding, periodic review and event-driven review, including beneficial ownership and control assessment.
- Policies, procedures and playbooks: Drafting TFS policies, internal controls, escalation protocols and CNMR or PNMR filing playbooks aligned with Cabinet Decision No. 74 of 2020 and the July 2025 EOCN Guidance.
- Staff training: Delivering role-based training on sanctions screening, match handling, tipping-off avoidance and goAML reporting obligations.
- AML software selection: Advising on the selection and configuration of real-time screening solutions, supporting documentation and audit readiness.
FAQs on UNSC Sanctions and UAE AML Compliance
The UNSC holds primary responsibility under the UN Charter for the maintenance of international peace and security. It adopts legally binding resolutions, including those that impose targeted financial sanctions used by regulated entities globally to detect and prevent financial crime.
The five permanent members (P5) of the UNSC are China, France, the Russian Federation, the United Kingdom and the United States. Each holds veto power over substantive Council resolutions.
The UNSC imposes sanctions through binding resolutions adopted under Chapter VII of the UN Charter. Measures typically include asset freezes, travel bans, arms embargoes and sectoral restrictions, administered by subsidiary Sanctions Committees.
The UN Consolidated List comprises all individuals and entities designated by the UNSC or its Sanctions Committees. The UAE Local Terrorist List is issued by the UAE Cabinet (on a proposal of the Supreme Council for National Security) under UNSCR 1373 (2001) and contains domestically designated terrorists, terrorist organisations and groups. UAE Reporting Entities must screen against both lists.
Under Article 1 of Cabinet Decision No. 74 of 2020, ‘without delay’ means applying freezing measures immediately, or in any case within 24 hours of the listing decision being issued by the UNSC, the relevant Sanctions Committee or the UAE Cabinet. Freezing must occur without prior notice to the designated person.
A Confirmed Name Match Report (CNMR) is the goAML report filed when a confirmed match with the UN Consolidated List or the UAE Local Terrorist List is identified. Reporting Entities must freeze without delay, reject or terminate the relationship, and submit the CNMR through goAML within five business days, enclosing the required supporting documents.
A PNMR applies where a potential match cannot be conclusively confirmed or dismissed. For an existing customer, the Reporting Entity should suspend the transaction and file the PNMR within the applicable timeline. For a potential customer or counterparty, identification documents should first be sought, and if they cannot be obtained within a reasonable time of 10 business days, the transaction or service should be rejected, and the PNMR filed accordingly.
Yes. Virtual Asset Service Providers (VASPs) are expressly covered by Cabinet Decision No. 74 of 2020 and by the expanded scope of Federal Decree-Law No. 10 of 2025. They must register with the Executive Office and on goAML, screen against applicable sanctions lists, freeze matches without delay and file CNMRs or PNMRs as applicable.
Screening must be conducted on an ongoing basis, including at onboarding, before processing relevant transactions, at periodic review and immediately upon notification of any listing, re-listing, update or de-listing. Reporting Entities must also maintain procedures to ensure compliance on weekends and public holidays where access to funds or business activity is possible.
Penalties under Cabinet Decision No. 74 of 2020 include imprisonment and fines ranging from AED 50,000 to AED 5 million. Federal Decree-Law No. 10 of 2025 also imposes substantial penalties on legal persons (up to AED 100 million for core offences), along with personal liability and potential removal of board members and senior executives.
Strengthen Your UNSC Sanctions Compliance with AML UAE
Effective sanctions compliance is not a one-off exercise. It requires ongoing screening, properly calibrated systems, well-trained staff and clear governance. AML UAE partners with financial institutions, DNFBPs and VASPs to build sanctions programmes that are defensible before supervisors and resilient in daily operations.
To discuss your UNSC sanctions compliance arrangements, contact AML UAE at info@amluae.com.
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About the Author
Pathik Shah
FCA, CAMS, CISA, CS, DISA (ICAI), FAFP (ICAI)
Pathik is an ACAMS-certified AML consultant specialising in governance, risk, and compliance for regulated entities in the UAE. He brings over 28 years of experience, with 1,000+ hours of AML training and 200+ advisory engagements across DNFBPs, VASPs, and FIs. He supports businesses in aligning with AML/CFT requirements from the CBUAE, DFSA, MoET, MoJ, VARA, CMA, FSRA, and FATF. Known for translating complex regulations into audit-ready procedures, Pathik enables operational clarity and compliance readiness.
Reach Out to Pathik