CMA Circular No. 3/2021 of 2021 · UAE Federal
SCA notice to licensed entities and exchanges setting the immediate reporting mechanism for financial institutions implementing Cabinet Resolution No. 74 of 2020 on terrorism lists.
Notice No. 3 of 2021 tells every entity licensed by the Securities and Commodities Authority (now the Capital Market Authority) and every licensed exchange that sanctions-match reports under Cabinet Decision No. 74 of 2020 must be filed through the goAML system, and that firms must build this into their procedures.
The notice is dated 26 July 2021 (reference 3-2021). It points to Article 21, clause 5 of Cabinet Decision No. 74 of 2020 on the terrorism lists and the implementation of UN Security Council resolutions, which lists the reporting obligations of financial institutions and DNFBPs for matched names and for the actions taken on them. The Authority informs licensees that goAML has been upgraded with a new reporting feature for these obligations, and that reports filed through it go directly to the Executive Office of the Committee for Goods subject to Import and Export Control.
Licensed entities are told to do three things: update their policies and procedures to incorporate the new goAML reporting feature; confirm that the feature is available under their own goAML access and that staff are familiar with it; and implement the reporting process accordingly.
The notice sets no deadline of its own and no penalty. It was followed on 4 August 2021 by Notice No. 4 of 2021, which sets out the actual procedure: a Funds Freeze Report for a confirmed match and a Partial Name Match Report for a potential match. Since 1 August 2025, Notice No. 1 of 2025 governs these reports: the Funds Freeze Report is now the Confirmed Name Match Report, both reports are due within five business days, and freezing must happen within 24 hours of designation. The index lists the notice as in force, and Cabinet Decision No. 74 of 2020 on which it rests remains in force.
All entities licensed by the Securities and Commodities Authority (now the Capital Market Authority) and all licensed securities and commodities exchanges, as financial institutions bound by the targeted financial sanctions reporting duties in Cabinet Decision No. 74 of 2020.
Arabic original text in 2 passages. Open the full text or jump to a provision:
| Paragraph 1 | Refers licensees to Article 21, clause 5 of Cabinet Decision No. 74 of 2020, which lists the reporting obligations of financial institutions and DNFBPs for matched names and the actions taken on them. |
| Paragraph 2 | Announces that goAML has been upgraded with a new feature for these sanctions reports, which are submitted directly to the Executive Office of the Committee for Goods subject to Import and Export Control. |
| Paragraph 3 | Directs licensed entities to update policies and procedures for the new goAML feature, confirm its availability under their goAML access, become familiar with it and implement the reporting process. |
Polaris is not licensed by the CMA and files no reports on behalf of regulated firms. Where a client is setting up or running a CMA-licensed business, we check that its AML/CFT policy pack covers goAML registration and the sanctions reporting route in Cabinet Decision No. 74 of 2020, and we coordinate with the client's MLRO or external compliance firm to close gaps. As a corporate service provider registered on goAML ourselves, we apply the same screening and reporting discipline to our own clients, which keeps the corporate, UBO and AML records we hold for them consistent with what their regulator expects.
No amendments, repeals or cross-references recorded for this instrument.
“Cites” and “Cited by” are built automatically from references in the full texts held in this library; they cover only instruments in the library.
Targeted Financial Sanctions Regulation
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-…
Notice 4/2021 on TFS reporting
SCA notice setting the procedure for reporting targeted financial sanctions matches through the goAML platform, including the steps licensed entities must take on a confi…
Notice 5/2021 on UNSCRs 1267, 1989 and 1988
SCA notice on sanctions under UNSC Resolutions 1267 (1999), 1989 (2011) and 1988 (2011), advising entities to apply enhanced screening to all parties to transactions.
Notice 1/2022 on TFS under UNSCRs 1718 and 2231
SCA notice to all licensed entities and exchanges on implementing targeted financial sanctions under UNSC Resolutions 1718 (2006) and 2231 (2015).
Notice 1/2025 on enhanced TFS obligations
Notice on enhanced obligations under the UAE targeted financial sanctions guidance updated on 1 August 2025.
AML/CFT/CPF Law 2025
The UAE's principal AML law in 42 articles. It criminalises money laundering, terrorism and proliferation financing, imposes risk assessment, customer due diligence, reco…
Thematic Review on TFS Implementation (Securities Sector)
Thematic review assessing how capital market firms understand and comply with targeted financial sanctions obligations under Cabinet Resolution No. 74 of 2020.
Whether you are establishing a new venture, restructuring an existing enterprise, or exploring residency pathways — we are here to advise.
Arrange a Consultation →