United Nations Security Council Resolutions (UNSCRs)
Last Updated: 04/07/2026
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Key Takeaways: United Nations Security Council Resolutions (UNSCRs)
- Relevant UNSCRs adopted under Chapter VII of the UN Charter are legally binding on all UN Member States, including the UAE, and give rise to mandatory targeted financial sanctions (TFS) obligations under FATF Recommendations 6 and 7.
- The UAE implements UNSCR-based TFS through Cabinet Resolution No. 74 of 2020, converting international obligations into enforceable domestic law applicable to all regulated entities — FIs and DNFBPs alike.
- UAE-regulated entities must screen all parties — customers, beneficial owners, and transaction counterparties — against the UN Consolidated List and the UAE Local Terrorist List, and must freeze assets without delay upon identification of a true match.
- The Executive Office for Control and Non-Proliferation (EOCN) is the UAE’s designated competent authority for TFS implementation and coordinates enforcement across sector supervisory authorities.
- Non-compliance with UNSCR obligations carries criminal penalties under Article 33 of Federal Decree-Law No. 10 of 2025 — a fine of not less than AED 20,000, imprisonment, or both — in addition to administrative sanctions, including licence suspension or cancellation.
Why United Nations Security Council Resolutions (UNSCRs) Matter for AML and Sanctions Compliance in the UAE
United Nations Security Council Resolutions are decisions adopted by the UN Security Council. United Nations Security Council Resolutions adopted under Chapter VII of the UN Charter carry binding force on all UN Member States by operation of Article 25 and Article 103 of the Charter. Chapter VII is invoked when the Security Council determines that a threat to international peace and security exists.
Resolutions adopted under other provisions of the Charter, including those under Chapter VI, are not legally binding in the same mandatory sense. For regulated entities in the UAE, this distinction is operationally critical: only resolutions with Chapter VII authority give rise to mandatory targeted financial sanctions obligations, and those are the resolutions that Cabinet Resolution No. 74 of 2020 domestically implements.
Regulated entities in the UAE must implement sanctions screening, identify designated persons and entities, freeze without delay where required, prohibit making funds or economic resources available, and comply with reporting, escalation, and internal control requirements under UAE law.
What are United Nations Security Council Resolutions (UNSCRs)? Legal Basis and the Binding Force Under the UN Charter
United Nations Security Council Resolutions are formal decisions adopted by the fifteen-member UN Security Council. The Security Council bears primary responsibility under the UN Charter for the maintenance of international peace and security.
Article 25 of the UN Charter provides that UN Member States agree to accept and carry out the decisions of the Security Council. Where resolutions are adopted under Chapter VII — which covers actions with respect to threats to the peace, breaches of the peace, and acts of aggression — they carry mandatory binding force on all 193 UN Member States by operation of Article 103 of the Charter, which provides that Charter obligations prevail over any other international agreement.
Not all Security Council resolutions are binding in the same sense. Resolutions adopted under Chapter VI (pacific settlement of disputes) or through presidential statements are not legally mandatory obligations. For compliance purposes, regulated entities should focus on those resolutions adopted under Chapter VII that establish sanctions regimes, as these are the instruments that give rise to targeted financial sanctions obligations.
How UNSCRs Support AML, CFT, and CPF Objectives
The relevant UNSCRs impose sanctions through Targeted Financial Sanctions (TFS).
The United Nations Security Council (UNSC) has adopted several resolutions that work on disrupting the networks that promote terrorism and proliferation financing.
Relevant resolutions may require measures such as asset freezes and related restrictions against designated persons and entities.
Relevant UNSCRs require targeted financial sanctions against designated persons and entities in order to prevent and suppress terrorism, terrorist financing, and proliferation financing.
The compliance process includes sanctions screening at onboarding, ongoing screening and transaction-related checks, escalation of true or potential matches, immediate freezing where required, and prompt reporting in line with UAE law.
Counter-Proliferation Financing (CPF) Obligations
FATF Recommendation 7 requires countries to implement targeted financial sanctions related to the financing of proliferation of weapons of mass destruction (WMD), separately from and in addition to the CFT obligations under Recommendation 6. These CPF obligations arise principally from the DPRK and Iran sanctions regimes.
For regulated entities in the UAE, CPF obligations include screening against relevant UN lists, refraining from making funds or economic resources available to designated persons and entities, and applying enhanced due diligence to customers or transactions with connections to high-risk jurisdictions identified in the context of WMD proliferation. Federal Decree-Law No. 10 of 2025 addresses these obligations alongside the broader AML/CFT framework.
CPF obligations are distinct from general AML/CFT controls. They apply irrespective of whether a transaction or activity is suspected of being criminal in the traditional sense — the sole trigger is the involvement of a designated person or entity. Regulated entities should ensure that their compliance frameworks explicitly address CPF as a stand-alone workstream.
UAE Implementation: Cabinet Resolution No. 74 of 2020 and the EOCN
As a UN Member State, the UAE is required to implement relevant Security Council decisions, and its domestic framework requires implementation without delay.
The Cabinet Resolution No. 74 of 2020 exists as a mandate that converts these international obligations into a federal mandate. This allows it to be enforced throughout the UAE.
The role of Supervisory Authorities is to supervise, inspect, follow up on compliance, and impose administrative penalties. Under Article 22 of Cabinet Resolution No. 74 of 2020, supervisory authorities receive information from financial institutions and DNFBPs, monitor implementation, conduct office and field inspections, and may impose appropriate administrative penalties where the resolution is violated or not implemented.
A key UAE-specific authority in the UNSCR implementation architecture is the Executive Office for Control and Non-Proliferation (EOCN). The EOCN is the UAE’s designated competent authority responsible for coordinating the implementation of UN and domestic targeted financial sanctions. The EOCN publishes the UAE Local Terrorist List, issues implementation guidance, and liaises with the UN Sanctions Monitoring Teams.
Regulated entities are required to submit reports on frozen assets and any sanctions-related actions to the EOCN in accordance with the timelines and formats it prescribes. All true-match identification events should be escalated internally and reported to the EOCN without delay, in parallel with any obligations to notify sector-specific supervisory authorities.
Regulated entities must understand their screening, freezing, reporting, escalation, and internal control obligations under the UAE targeted financial sanctions framework.
Active UNSC sanctions regimes relevant to UAE-regulated entities include, but are not limited to, the following:
Terrorism and Terrorist Financing
- UNSCR 1267 (1999) and successor resolutions, including UNSCR 1989 (2011) and UNSCR 2253 (2015) — ISIL (Da’esh) and Al-Qaida Sanctions regime. This is the primary consolidated terrorism sanctions list and is operationally the most significant for UAE DNFBPs and financial institutions.
- UNSCR 1373 (2001) — Counter-terrorism framework requiring states to maintain domestic terrorist lists. In the UAE, this is implemented through the Local Terrorist List under Cabinet Resolution No. 74 of 2020.
- UNSCR 1988 (2011) — Taliban Sanctions regime (Afghanistan).
- UNSCR 2713 (2023) — Al-Shabaab Sanctions Committee under the Somalia framework.
Proliferation Financing
- UNSCR 1718 (2006) and successor resolutions — Democratic People’s Republic of Korea (DPRK). Includes arms embargoes, asset freezes, and travel bans; significant for trade finance and correspondent banking.
- UNSCR 1737 (2006) and successor resolutions — Islamic Republic of Iran. Remaining restrictions post-JCPOA focus on ballistic missile and arms-related designations.
Country-Specific Regimes
- UNSCR 1518 (2003): Iraq
- UNSCR 1533 (2004): The Democratic Republic of Congo (DRC)
- UNSCR 1591(2005): Sudan
- UNSCR 1636 (2005): Lebanon
- UNSCR 1970 (2011): Libya
- UNSCR 2048 (2012): Guinea-Bissau
- UNSCR 2140 (2014): Yemen
- UNSCR 2206 (2015): South Sudan
- UNSCR 2653 (2022): Haiti
- UNSCR 2745 (2024): Central African Republic (CAR)
Regulated entities must maintain screening coverage across all active UNSC sanctions lists, not only those considered geographically proximate. The UN Consolidated List encompasses all active regimes and should be used as the primary reference, supplemented by the UAE Local Terrorist List.
TFS: Freezing Obligations, Screening Scope and List Coverage
Targeted financial sanctions are measures requiring the freezing of funds or other assets of designated persons and entities, and prohibiting funds or economic resources from being made available to them, directly or indirectly.
Regulated entities in the UAE must screen against two distinct categories of lists. The UN Consolidated Sanctions List contains all individuals, entities, and groups designated under active UNSC sanctions regimes, including the ISIL (Da’esh) and Al-Qaida Sanctions List (maintained under UNSCR 1267/1989/2253), the 1988 Sanctions List (Taliban), and country-specific sanctions committees. Separately, the UAE Local Terrorist List is maintained under Cabinet Resolution No. 74 of 2020 and includes domestically designated persons and entities under UNSCR 1373 (2001). Both lists carry immediate freeze obligations. The listing and delisting procedures, competent authorities, and escalation pathways differ between the two regimes, and regulated entities must maintain screening coverage across both without conflation.
The UAE framework requires screening and ongoing name checks not only for customers, but also for transaction parties, potential clients, beneficial owners, and persons or organisations with direct or indirect relationships to the customer or transaction.
Under Article 4 of Cabinet Resolution No. 74 of 2020, regulated entities must freeze the funds and economic resources of designated persons and entities immediately upon identification of a true match, without prior notice or waiting for regulatory instruction.
In practice, the EOCN and UAE supervisory authorities interpret “without delay” to mean within hours of the match being identified. Entities must therefore ensure that their screening systems and internal escalation protocols are calibrated to support same-session or same-day response capability.
Penalties and Risks of UNSCR Non-Compliance in the UAE
The UNSCRs are imposed in the UAE through Cabinet Resolution No. 74 of 2020, which confers Regulatory Authorities with the power to impose administrative penalties on failure to implement compliance measures corresponding to it.
The penalty framework for UNSCR non-compliance in the UAE operates across two tracks.
- Criminal liability under Article 33 of Federal Decree-Law No. 10 of 2025 provides that any person who violates instructions issued by the Executive Office or any competent authority related to targeted financial sanctions may be punished by imprisonment, a fine of not less than AED 20,000, or both.
- Administrative sanctions under Cabinet Resolution No. 74 of 2020 and sector-specific supervisory frameworks, including the Central Bank of the UAE, the SCA, and DNFBP supervisory authorities, include warnings, financial penalties, license suspension or cancellation, and mandatory remediation. The EOCN coordinates enforcement across competent authorities and may refer matters for criminal prosecution. Regulated entities should treat the AED 20,000 statutory minimum as a floor, not a ceiling: enforcement actions in the UAE and internationally have resulted in penalties orders of magnitude higher, alongside reputational and operational consequences.
How AML UAE Helps You Build a Sanctions Compliant Framework
Organisations need to have professionally designed sanctions compliance frameworks in place, which can be implemented to support their fight against financial crime and adhere to international and domestic standards set forth.
This includes integrating systems that can track and manage UNSCR lists, incorporating tools to perform real-time screening, implementing policies and procedures, and regularly training staff.
Many organisations struggle to enforce compliance obligations, which are multifaceted. Leveraging our expert services at AML UAE for managing KYC and CDD and providing customised training helps organisations re-position themselves as fully compliant with international obligations, i.e., UNSCRs, and in the context of the UAE, domestic obligations such as Cabinet Resolution No. 74 of 2020.
Strengthening UAE AML Programs Through Proactive Sanctions Governance
In the UAE, the UNSCRs are binding through the Cabinet Resolution No. 74 of 2020, which imposes the same domestically.
It is essential not to underestimate and indeed to actively reinforce the value of proactive sanctions governance, which collectively includes screening, risk profiling, reporting, and implementing corresponding measures.
Moreover, at the core of AML compliance lie several requirements, including enterprise-wide risk management, synonymously known as business risk assessment.
Organisations can redefine and customise their compliance obligations by leveraging services provided by experts at AML UAE for Sanctions Screening, regulatory reporting, and managing other compliance requirements, safeguarding the organisation from ML/TF risks.
Frequently Asked Questions - UNSCRs
UNSCRs are resolutions issued to maintain international peace and security. They are aimed at combating terrorism and terrorist financing, proliferation financing, and risks associated with individuals, companies, and entities. Certain UNSCRs require countries to implement targeted financial sanctions (TFS).
They shape a country’s sanctions and AML/CFT framework. Further, some UNSC decisions taken under Chapter VII are binding on UN member states.
Yes, United Nations Security Council Resolutions are legally binding on UAE companies by way of Cabinet Resolution No. 74 of 2020.
UNSCRs are imposed in the UAE through Cabinet Resolution No. 74 of 2020 to uphold AML and sanctions compliance.
Targeted Financial Sanctions are measures imposed under relevant UNSCR regimes and implemented domestically through Cabinet Resolution No. 74 of 2020 requiring the immediate freezing of funds and economic resources of designated persons and entities, and prohibiting such assets from being made available to them, directly or indirectly. TFS address terrorism financing (under FATF Recommendation 6) and proliferation financing (under FATF Recommendation 7). They operate independently from the broader AML controls applicable to money laundering, and non-compliance triggers distinct legal consequences.
UAE-regulated entities must screen all relevant parties, including customers, beneficial owners, transaction counterparties, and connected persons, against the UN Consolidated List, the UAE Local Terrorist List, and any other applicable sanctions lists. Screening must occur at onboarding, at regular intervals, and in real time or near-real time at the point of transaction.
For entities of any meaningful scale, manual screening is insufficient to meet the “without delay” standard. Automated screening solutions integrated with regularly updated list feeds are the expected standard for most regulated entities. Where manual screening is used, entities must document the controls and frequency applied and demonstrate that these are proportionate to their risk profile.
UNSCR non-compliance in the UAE triggers liability across two tracks. Criminally, Article 33 of Federal Decree-Law No. 10 of 2025 provides for imprisonment, a fine of not less than AED 20,000, or both.
Administratively, Cabinet Resolution No. 74 of 2020 and sector-specific supervisory frameworks empower competent authorities, including the CBUAE, SCA, and DNFBP supervisors, to impose warnings, financial penalties, licence suspension or cancellation, and mandatory remediation. The AED 20,000 is a statutory floor; actual enforcement actions in the UAE and internationally have resulted in significantly higher penalties.
The Executive Office for Control and Non-Proliferation (EOCN) is the UAE’s designated competent authority for the implementation of targeted financial sanctions. It maintains the UAE Local Terrorist List, issues implementation guidance to regulated entities, and coordinates with UN Sanctions Monitoring Teams. Regulated entities must report frozen assets and true-match actions to the EOCN without delay.
FATF Recommendation 6 requires countries to implement targeted financial sanctions related to terrorism and terrorist financing, giving effect to relevant UNSCRs, principally UNSCR 1267 and UNSCR 1373.
FATF Recommendation 7 requires countries to implement targeted financial sanctions related to proliferation financing of weapons of mass destruction, principally giving effect to the DPRK and Iran sanctions regimes under UNSCRs 1718 and 1737. Both obligations apply to UAE-regulated entities under Cabinet Resolution No. 74 of 2020 and Federal Decree-Law No. 10 of 2025.
The UN Consolidated List is the unified reference document maintained by the UN Security Council that contains all individuals, groups, and entities designated under active UNSC sanctions regimes. UAE-regulated entities must screen against the UN Consolidated List as a primary reference, in addition to the UAE Local Terrorist List. The list is updated in real time and must be incorporated into screening systems with corresponding refresh frequencies.
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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.
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