CMA Circular No. 1/2025 of 2025 · UAE Federal
Notice on enhanced obligations under the UAE targeted financial sanctions guidance updated on 1 August 2025.
Notice No. 1 of 2025 brings the updated targeted financial sanctions guidance issued by the Executive Office for Control and Non-Proliferation (EOCN) in July 2025 into force for every financial entity, exchange and virtual asset service provider licensed by the Securities and Commodities Authority (now the Capital Market Authority), with immediate effect. The core changes are that a freeze must happen within 24 hours of designation, and that confirmed matches are now reported by a Confirmed Name Match Report within five business days.
The notice is dated 1 August 2025 and continues the Authority's earlier sanctions notices under Cabinet Decision No. 74 of 2020. It sets twelve obligations. Firms must freeze all funds and other assets, including virtual assets, without delay, meaning within 24 hours of a designation on the UAE Local Terrorist List or the UN Security Council Consolidated List. Confirmed matches are reported through goAML by a Confirmed Name Match Report (CNMR, formerly the Funds Freeze Report) within five business days of the freeze. Potential matches are reported by a Partial Name Match Report within five business days of the suspension, and suspicious links to designated persons by an immediate STR or SAR.
Screening must run without interruption, including at weekends and on holidays, and every party must be screened before a transaction. Firms must identify and assess all control relationships, including signatories, powers of attorney and beneficial ownership, and distinguish minority from majority control. They must also apply enhanced due diligence to transactions linked to high-risk jurisdictions, monitor the EOCN's Notification Alert System, check dual-use goods permits under Federal Law No. 13 of 2007 and Cabinet Resolution No. 50 of 2020, follow the EOCN grievance guidance, and keep screening results, including false positives, for at least five years.
The notice states that breaches of Cabinet Decision No. 74 of 2020 may lead to imprisonment of 1 to 7 years and/or a fine of AED 50,000 to AED 5,000,000, while firms acting in good faith are exempt from liability. It replaces the two-business-day Funds Freeze Report timing in Notices 4 and 5 of 2021.
All financial entities, securities and commodities exchanges and virtual asset service providers licensed by the Securities and Commodities Authority (now the Capital Market Authority), in implementing targeted financial sanctions under Cabinet Decision No. 74 of 2020 and the EOCN's July 2025 guidance.
English official text in 3 passages. Open the full text or jump to a provision:
| Item 1 | Freeze all funds and other assets without delay, within 24 hours of designation on the UAE Local Terrorist List or the UN Consolidated List, covering all asset types under the firm's control, including virtual assets. |
| Item 2 | Report confirmed matches by Confirmed Name Match Report (formerly FFR) within 5 business days of the freeze and potential matches by PNMR within 5 business days of suspension; file STRs or SARs immediately. |
| Item 3 | Screening systems must operate without interruption, including at weekends and on holidays, and all parties to a financial transaction must be screened before it is carried out. |
| Item 4 | Identify and assess all control relationships, including signatories, powers of attorney and beneficial ownership, distinguishing minority from majority control and reassessing risk accordingly. |
| Item 6 | Apply enhanced due diligence to all financial and trade transactions involving jurisdictions or parties linked to high-risk jurisdictions. |
| Item 7 | Maintain internal mechanisms to monitor and act on real-time alerts issued by the EOCN through its Notification Alert System. |
| Item 8 | Items 8 and 9: customers trading dual-use items must hold a valid permit under Federal Law No. 13 of 2007 and Cabinet Resolution No. 50 of 2020; suspicious cross-border dual-use transactions must be verified. |
| Item 11 | Keep records of all screening results, including confirmed matches, partial matches and false positives, for at least five years. |
| Item 12 | Breaches of Cabinet Decision No. 74 of 2020 may lead to imprisonment of 1 to 7 years and/or fines of AED 50,000 to 5,000,000; good-faith implementation is exempt from criminal, civil or administrative liability. |
The notice states that violation of, or non-compliance with, the obligations in Cabinet Decision No. 74 of 2020 may result in imprisonment from 1 to 7 years and/or a fine of AED 50,000 to AED 5,000,000. Firms acting in good faith in implementing targeted financial sanctions are exempt from criminal, civil and administrative liability.
Polaris is not licensed by the CMA, but as a corporate service provider we are bound by the same Cabinet Decision No. 74 of 2020, so the 24-hour freeze, the CNMR and PNMR timelines and the five-year record rule shape our own procedures. The control-relationship requirement matters most for our clients. Their banks, brokers and VASPs must now map signatories, attorneys and beneficial owners, so we keep each company's register of signatories, powers of attorney and UBOs current and consistent, which avoids screening holds when clients transact.
No amendments, repeals or cross-references recorded for this instrument.
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