CMA Circular No. 1/2022 of 2022 · UAE Federal
SCA notice to all licensed entities and exchanges on implementing targeted financial sanctions under UNSC Resolutions 1718 (2006) and 2231 (2015).
Notice No. 1 of 2022 requires CMA-licensed entities (then SCA-licensed) and licensed exchanges to apply targeted financial sanctions under the UN proliferation regimes in Security Council Resolutions 1718 (2006) and 2231 (2015): screen every party to a transaction, apply enhanced due diligence to transactions linked to the relevant countries, check cross-border flows for unauthorised dual-use goods trading, and report matches through goAML.
The notice is dated 19 May 2022 and continues the Authority's earlier notices on targeted financial sanctions and proliferation financing, under Cabinet Decision No. 74 of 2020. Firms must screen all parties to a financial transaction or service against persons and entities listed under the two resolutions; apply enhanced due diligence to all financial transactions, including trade transactions, linked to the relevant countries; and verify cross-border transactions suspected of relating to unauthorised trading of dual-use goods.
Matches must be reported without delay: a confirmed match by Funds Freeze Report within five business days of implementing the freeze, a potential match by Partial Name Match Report within five business days of the suspension, and related suspicious activity by STR or SAR to the Financial Intelligence Unit. Earlier Notices 4 and 5 of 2021 set a two-business-day window for the same reports under other regimes, and since 1 August 2025 Notice No. 1 of 2025 sets five business days for both reports across the board, renaming the Funds Freeze Report the Confirmed Name Match Report.
The notice also requires firms to make sure customers dealing in dual-use items hold a valid permit, pointing to the UAE Control List published by the Executive Office for Control and Non-Proliferation under Cabinet Resolution No. 50 of 2020 and Federal Law No. 13 of 2007, and lists the Executive Office's typologies and counter-proliferation guidance. Compliance was required on issue; the notice has no penalty clause of its own.
All entities licensed by the Securities and Commodities Authority (now the Capital Market Authority) and licensed securities and commodities exchanges, in their screening, due diligence and reporting for persons designated under UN Security Council Resolutions 1718 (2006) and 2231 (2015).
English official text in 3 passages. Open the full text or jump to a provision:
| Paragraph 1 | Requires screening of all parties to a financial transaction or service to ensure they are not linked to persons or entities listed under UNSCR 1718 (2006) and 2231 (2015). |
| Paragraph 2 | Requires enhanced due diligence on all financial transactions, including trade transactions, linked to the relevant countries, and verification of cross-border transactions suspected of unauthorised dual-use goods trading. |
| Paragraph 3 | Confirmed matches are reported by Funds Freeze Report within five business days of the freeze; potential matches by Partial Name Match Report within five business days of suspension; suspicious activity by STR or SAR. |
| Paragraph 4 | Firms must ensure customers dealing in dual-use items hold a valid permit, using the UAE Control List under Cabinet Resolution No. 50 of 2020 and Federal Law No. 13 of 2007. |
| Paragraph 5 | Points firms to the Executive Office's guidance on sanctions circumvention typologies, counter-proliferation financing for FIs, DNFBPs and VASPs, and its strategic review of case studies. |
| Paragraph 6 | Firms must not provide any transaction or service that could contribute to evading the sanctions under the two resolutions, and must comply from the date of issue. |
Polaris is not licensed by the CMA. The notice is relevant to us because trading and logistics companies, including those dealing in goods that may appear on the UAE Control List, form part of the corporate service work we do. When we form or administer such a company, we ask early whether its goods need an export-control permit, record the answer in the KYC file, and make sure the licence activities match what the business actually trades. For clients in the capital markets sector, we coordinate with their compliance adviser so the AML manual covers proliferation financing screening and dual-use checks.
| Amended by | CMA Notice No. 1 of 2025 |
“Cites” and “Cited by” are built automatically from references in the full texts held in this library; they cover only instruments in the library.
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