Targeted Financial Sanctions for DNFBPs: An Overview
All Designated Non-Financial Businesses and Professions need to comply with the obligations as per Cabinet Decision No. 74 of 2020 for UNSCRs 1718 (2006) & 2231 (2015).
Industries subject to these sanctions include dealers of precious metals and precious stones, real estate brokers and agents, corporate services providers, auditing or accounting firms, and legal consultancy companies.
The requirements include:
- Implementing screening procedures across all parties of a transaction or provided services according to the definition of a DNFBP in Article (3) of Cabinet Decision No (10) of 2019 concerning the Implementing regulations for ensuring they are not associated with persons or entities or firms listed under UNSCR 1718 (2006) & 2231 (2015).
- Verifying cross-border transactions suspected of being related to unauthorized trading of dual-use goods.
- Implementing Enhanced Due-Diligence procedures on all transactions, including trade transactions linked to Iran and North Korea.
What are dual-use items?
The UAE has enforced regulations on the export and import control of dual-use items. These rulings specify the licensing & reporting requirements for individuals involved in the import, export, transit, & trans-shipment of all kinds of dual-use Items within the jurisdiction of the UAE.
All Designated Non-Financial Businesses must ensure that clients 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 the list of dual-use items UAE Control List available on its website as per Cabinet Resolution No. 50 for 2020 regarding the control list annexed to Federal Law No. 13 for 2007 relating to commodities subjected to import & export control & dual-use chemicals subject to import and export control.
Immediately report all potential or confirmed matches related to any individuals or entities designated according to the UNSCRs mentioned above. Reporting covers:
- Any potential match by raising a Partial Name Match Report through GoAML within five business days from implementing any suspension measures.
- Any confirmed match by raising a Funds Freeze Report through GoAML within five business days from implementing any freeze measures.
- Any suspicious activities or transactions might be related to designated individuals or entities according to the UNSCRs mentioned above. These can be reported by raising a Suspicious Transaction Report/Suspicious Activity Report to the UAE Financial Intelligence Unit through GoAML.
Guidance Documents
The Executive Office of the Committee For Goods & Materials Subjected To Import & Export Control has published many guidance documents concerning targeted financial sanctions. DNFBPs can refer to these guidance documents:
- Guidance on Counter Proliferation Financing for FIs, DNFBPs, and VASPs.
- Typologies on circumventing targeted sanctions.
- UAE’s strategic review on targeted financial sanctions.
All DNFBPs should prevent the provision of all transactions or services that can contribute to the evasion of Targeted Financial Sanctions imposed according to UNSCR 2231 (2015) & UNSCR 1718 (2006).
All DNFBPs need to comply with the mentioned requirements upon the issuance of this notice. To know more, reach out to us.