Circular 1 of 2022: Implementation of Targeted Financial Sanctions on UNSCRs 1718 (2006) and 2231 (2015)

Circular No. (1) of 2022 requires all Designated Non-Financial Businesses and Professions (DNFBPs) to comply with the following Targeted Financial Sanctions (TFS) obligations in accordance with Cabinet Decision No. 74 of 2020 for UNSCRs 1718 (2006) and 2231 (2015).

Accordingly, Real estate brokers and agents, Dealers of precious metals and precious stones, Auditing or accounting firms, Corporate services providers, Legal consultancy companies have to ensure that they apply screening procedures to all parties of a transaction to ensure that they are not linked with persons or entities or organisations listed under UNSCRs 1718 (2006) and 2231 (2015).

Further, DNFBPS are also required to carry out enhanced due diligence (EDD) procedures on all transactions, including trade transactions linked to North Korea and Iran. Read complete guide to effective customer due diligence.

DNFBPS have to verify cross-border transactions suspected of being related to unauthorised trading of Dual-Use Goods.

They also have to report immediately (without delay) all confirmed or potential matches related to any individuals or entities designated pursuant to the above-mentioned UNSCRs. Reporting shall cover:

• Any confirmed match by raising a Funds Freeze Report (FFR) via GoAML within 5 business days from implementing any freeze measures.
• Any potential match by raising a Partial Name Match Report (PNMR) via GoAML within 5 business days from implementing any suspension measures. Read our article on Funds Freeze Report (FFR) and Partial Name Match Report (PNMR) filing with goAML.
• Any suspicious transactions or activity that may be related to designated individuals or entities pursuant to the above-mentioned UNSCRs by raising an STR/SAR via GoAML to the UAE Financial Intelligence Unit.

All DNFBPs should ensure that customers dealing in Dual-Use Items have a valid permit to conduct such trades. The Executive Office of The Committee For Goods & Materials Subjected To Import & Export Control has made available on its website the list of Dual-Use Items “UAE Control List” as per Cabinet Resolution No. 50 for 2020 concerning the control list annexed to Federal Law No. 13 for 2007 relating to commodities subjected to import & export control and Dual-Use chemicals subject to import & export control.

All DNFBPs should prevent the provision of any transaction or services that could contribute to the evasion of Targeted Financial Sanctions imposed pursuant to UNSCR 2231 (2015) and UNSCR 1718 (2006).