Governs the UAE Local Terrorist List and the implementation of UN Security Council sanctions: listing and delisting, the role of the Executive Office for Control and Non-Proliferation, immediate freezing without notice by financial institutions and DNFBPs, reporting of matches, grievances and access to frozen funds. Repealed Cabinet Decision No. 20 of 2019; still cited as current in 2026.
Cabinet Decision No. 74 of 2020 is the UAE's targeted financial sanctions regulation. In force from 27 October 2020 and still shown as in force on the Central Bank rulebook, it repealed Cabinet Decision No. 20 of 2019 (Article 25) and governs two lists: the UN Security Council Sanctions List and the UAE Local Terrorist List. It assigns the Supreme Council for National Security the power to propose listings and delistings (Articles 2 to 4), and the Executive Office for Control and Non-Proliferation the job of publishing lists, notifying listed persons, receiving grievances and collecting supervisory results (Article 11).
The operative duty for business is Article 15: any person must, without delay and without prior notice, freeze funds belonging to or controlled by a listed person, must not make funds or services available to them without the Executive Office's authorisation, and must report the freeze to the Office within five business days. Article 1 defines without delay as within 24 hours of the listing decision. Article 12 requires the Office to send lists without delay to supervisors, financial institutions and DNFBPs, who report outcomes within five business days.
Article 21 lists what financial institutions and DNFBPs must do: register with the Executive Office to receive notifications, screen customers and transactions against both lists, freeze without delay on a match, notify the supervisory authority immediately, maintain internal controls, avoid tipping off and cooperate. Article 22 requires supervisory authorities to forward information to the Office within five working days, supervise compliance and sanction non-compliance, and report at least semi-annually.
Protection and relief: Article 7 and Article 18 let persons wrongly matched by name ask for measures to be lifted, with a decision within 30 days and court recourse; Articles 8 and 19 allow access to frozen funds for basic expenses, legal fees and extraordinary expenses, subject to UN procedures for the Sanctions List; Article 6 gives listed persons a grievance to the Office and an appeal to the competent court within 60 days of rejection. Article 23 keeps information confidential, protects good-faith freezing from liability and states that violations are punished under the AML law (then Federal Decree-Law No. 20 of 2018, now Federal Decree-Law No. 10 of 2025).
Status: in force. The decision has not been amended on the rulebook; its fine schedule for DNFBPs is in Cabinet Resolution No. 71 of 2024, and the Ministry of Economy and Tourism's Circular No. 1 of 2026 recalls these duties alongside the high-risk country lists.
Any person in the UAE holding or dealing with funds, and in particular financial institutions, DNFBPs (including corporate service providers) and virtual asset service providers, their supervisory authorities, the Executive Office for Control and Non-Proliferation, the Supreme Council for National Security and persons placed on the UN Sanctions List or the UAE Local Terrorist List.
| Article 1 | Definitions, including Funds, Listed Person, Local Lists, Sanctions List, the Executive Office, and Without Delay, which means within 24 hours of the listing decision. |
| Article 3 | The Supreme Council proposes listings on the Local Terrorist List without notifying the person, on the criteria of UN Security Council Resolution 1373; the Cabinet issues the list and the Office publishes it. |
| Article 6 | A locally listed person may file a grievance with the Executive Office; the Cabinet decides, and the applicant may appeal to the competent court within 60 days of rejection or of a missed response deadline. |
| Article 12 | The Office sends the lists without delay to supervisory authorities, financial institutions, DNFBPs and law enforcement; those agencies report outcomes to the Office within five business days. |
| Article 15 | Any person must, without delay and without prior notice, freeze funds under the Sanctions List and Local Lists, report the freeze to the Office within five business days, and make no funds or services available to listed persons without the Office's authorisation. |
| Article 18 | A person wrongly matched to a name on the Sanctions List may ask the Office to lift the measures; the Office decides within 30 days, with recourse to the court. |
| Article 19 | The Office may authorise access to frozen funds for basic expenses, legal fees and extraordinary expenses, subject to notification of or approval by the relevant UN committee. |
| Article 21 | Financial institutions and DNFBPs must register with the Executive Office, screen customers and transactions, freeze without delay on a match, notify the supervisory authority immediately, keep internal controls, avoid tipping off and cooperate. |
| Article 22 | Supervisory authorities forward information to the Office within five working days, supervise and sanction non-compliance, and report to the Office at least semi-annually. |
| Article 23 | Information is confidential, good-faith freezing carries no liability, and violations attract the penal and administrative sanctions of the federal AML law. |
| Article 25 | Repeals Cabinet Decision No. 20 of 2019 and any provision that conflicts with the decision. |
The decision sets no amounts itself; Article 23(3) refers violations to the penal and administrative sanctions of the federal AML law. For DNFBPs supervised by the Ministry of Economy and Tourism, Cabinet Resolution No. 71 of 2024 fines failure to freeze promptly at AED 500,000 to AED 1,000,000, failure to screen or to register with the Executive Office at AED 50,000 to AED 1,000,000, and failure to report freezes at AED 50,000 to AED 100,000. Under Federal Decree-Law No. 10 of 2025, breaching targeted financial sanctions instructions is also a criminal offence (Article 33).
Sanctions screening under this decision is the first thing we do on any new file and the last thing before any transaction we execute as registered agent or corporate secretary. We screen every client, shareholder, director, beneficial owner and counterparty against the UN Consolidated List and the UAE Local Terrorist List at onboarding and on every list update, keep the screening record on the file, and we are registered with the Executive Office so that list changes reach our compliance officer directly. Our procedure for a potential match follows Articles 15 and 21 exactly: no notice to the client, an immediate freeze of anything we hold or control, a report to the Executive Office within five business days and a notification to our supervisor, then a false-positive request under Article 18 if the match is a name coincidence. We build the same workflow into the compliance manuals we write for DNFBP clients, because the fines for failing to freeze are the highest in the DNFBP schedule.
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