UAE DNFBPs: Urgent Compliance with latest UN Sanctions Reimposition and FATF Updates

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The recent circular on the re-imposition of UN sanctions significantly raises the bar for DNFBPs in the UAE, turning Targeted Financial Sanctions (TFS) implementation into an immediate governance, risk, and compliance priority rather than a routine control update. DNFBPs that respond decisively now will not only meet Ministry of Economy expectations but also strengthen their overall financial crime risk posture and protect their business from serious regulatory, operational, and reputational exposures

Immediate compliance expectations

The latest circular on the re‑imposition of UN sanctions places immediate, practical obligations on all DNFBPs supervised by the Ministry of Economy to strengthen Targeted Financial Sanctions (TFS) controls in line with AML/CFT/CPF requirements and Cabinet Resolution No. (74) of 2020.

DNFBPs are expected to act without delay on four key measures:

• Update all screening and verification tools so they include the most recent United Nations Consolidated Sanctions List, ensuring that list changes are reflected promptly in your environment.
• Re‑screen all customers, beneficial owners, vendors, and transaction counterparties, including existing relationships and ongoing transactions, against the latest UN list to identify any sanctions exposure.
• Apply freezing measures immediately on any confirmed matches and prohibit making funds or other assets available, directly or indirectly, to listed persons or entities, in line with targeted financial sanctions obligations.
• Report Confirmed Name Match Reports (CNMR) and Partial Name Match Reports (PNMR) to the Executive Office for Control and Non‑Proliferation via the goAML system, following the procedures in the TFS guidance.

Expectations for screening systems

Where DNFBPs use an automated screening system with perpetual or delta screening capabilities, the Ministry expects documented confirmation from the vendor that:

UN sanctions lists are updated regularly and without delay.

All customers, beneficial owners, vendors, and transaction counterparties are screened consistently against the updated lists.

For DNFBPs, this circular is a clear signal that sanctions implementation is a core compliance obligation and that supervisory bodies will expect evidence of prompt execution, robust documentation, and alignment with the UAE’s broader AML/CFT/CPF framework.

Contact Crowe UAE GRC Team for more details: [email protected]

Navigating UAE's Latest AML Updates for DNFBPs

UAE's Ministry of Economy (MOE) Circular No. (8) of 2025, aligned with National Committee Resolution No. (15) of 2025, reinforces compliance amid FATF list updates on high-risk jurisdictions. Designated Non-Financial Businesses and Professions (DNFBPs) must act swiftly to integrate these into risk frameworks, avoiding penalties under prevailing laws.

1) General Obligations

Designated Non-Financial Businesses and Professions shall comply with the following:

• Monitor and review the updated lists issued by the Financial Action Task Force (FATF) concerning high-risk countries and countries subject to increased monitoring, and any updates thereto, through the official FATF website or the official website of the National Committee.
• Take such lists into consideration when conducting risk assessments and when establishing and applying due diligence policies and procedures, as well as managing and mitigating risks associated with relevant business relationships and transactions.

 2) Measures Applicable to High-Risk Countries (Blacklist)

With respect to countries for which the Financial Action Task Force (FATF) calls for the application of countermeasures, Designated Non-Financial Businesses and Professions shall comply with the following:

• Apply enhanced due diligence measures to all business relationships and transactions related to such countries.
• Refrain from establishing branches, representative offices, or subsidiaries in high-risk countries.
• Strengthen internal reporting mechanisms and submit suspicious transaction reports to the Financial Intelligence Unit through the GoAML system, where appropriate.
• Refrain from relying on third parties located in high-risk countries to conduct customer due diligence procedures.
• Comply with targeted financial sanctions in accordance with United Nations Security Council resolutions and Cabinet Decision No. (74) of 2020.

3) Measures Applicable to Countries Subject to Increased Monitoring (Grey List)

With respect to countries subject to increased monitoring, Designated Non-Financial Businesses and Professions shall comply with the following:

• Apply enhanced due diligence measures proportionate to the level of risk arising from dealings with such countries.
• Consider the updates issued by the Financial Action Task Force (FATF) when assessing risks and reviewing relevant business relationships and transactions.

Please note that the failure to comply with the provisions of this Circular No. (8) of 2025 shall result in the imposition of administrative measures and penalties as prescribed under the applicable laws and regulations, without prejudice to any other legal liabilities.

Relevant Lists and Reference Links

Countries Subject to Increased Monitoring (Grey List): https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-october-2025.html

High-Risk Countries (Black List): https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/Call-for-action-october-2025.html

High-Risk Countries – National Committee Official Website: https://namlcftc.gov.ae/en/more/jurisdictions/high-risk-countries/

By acting decisively on the Ministry of Economy’s circular and strengthening sanctions compliance across people, process, and technology, DNFBPs can safeguard their licence to operate, protect their reputation, and contribute to the UAE’s broader efforts to uphold the integrity of the global financial system.