CMA Circular No. 5/2021 of 2021 · UAE Federal
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 No. 5 of 2021 requires CMA-licensed entities (then SCA-licensed) and licensed exchanges to apply enhanced sanctions screening to all parties to their transactions for persons designated under the UN Al-Qaida and Taliban regimes, and to report every confirmed or potential match through goAML within two business days.
The notice is dated 12 September 2021 (reference 5-2021). It was issued in view of the political developments in Afghanistan, to make targeted financial sanctions effective and to stop formal and informal channels being used to move or receive funds for designated persons. It covers individuals and entities designated under UN Security Council Resolutions 1267 (1999) and 1989 (2011) and their successor resolutions (Al-Qaida), and Resolution 1988 (2011) and its successors (Taliban).
The Authority directs all entities to conduct enhanced screening on all parties to transactions, including bank and wire transfers, inward and outward remittances, cash deposits and withdrawals and transactions by dealers in real estate and precious metals and stones; to verify that screening tools hold the latest UN Consolidated List data and can detect confirmed and potential matches; and to report without delay. A confirmed match is reported by a Funds Freeze Report within two business days of the freeze, a potential match by a Partial Name Match Report within two business days of the suspension, and any related suspicious activity by an STR or SAR to the Financial Intelligence Unit.
Entities must comply immediately and update their policies and procedures. The notice carries no penalty clause of its own. Its two-business-day timing matched Notice No. 4 of 2021. From 1 August 2025, Notice No. 1 of 2025 replaced it: freezing within 24 hours of designation, and five business days for the Confirmed Name Match Report (formerly the Funds Freeze Report) and the Partial Name Match Report.
All entities licensed by the Securities and Commodities Authority (now the Capital Market Authority) and licensed securities and commodities exchanges, in screening customers and all parties to transactions against persons designated under UN Security Council Resolutions 1267, 1989 and 1988.
English official text in 2 passages. Open the full text or jump to a provision:
| Paragraph 1 | States the purpose: effective targeted financial sanctions after the developments in Afghanistan, and preventing formal and informal channels from moving or receiving funds for designated persons. |
| Table | Identifies the regimes covered: Al-Qaida designations under UNSCR 1267 (1999), 1989 (2011) and successors, and Taliban designations under UNSCR 1988 (2011) and successors. |
| Paragraph 2 | Requires enhanced screening of all parties to transactions, including wire transfers, remittances, cash deposits and withdrawals and transactions by real estate dealers and dealers in precious metals and stones. |
| Paragraph 3 | Requires firms to verify that screening tool parameters hold the latest UN Consolidated List data and are sufficient to detect confirmed or potential matches. |
| Paragraph 4 | Confirmed matches go by Funds Freeze Report within two business days of the freeze; potential matches by Partial Name Match Report within two business days of suspension; suspicious activity by STR or SAR. |
| Paragraph 5 | All entities must ensure immediate compliance with the notice and update their relevant policies and procedures. |
Polaris is not licensed by the CMA and does not run regulated firms' screening. For clients forming or administering a CMA-licensed business, we check that the AML/CFT manual names the UN regimes the notice covers, that the screening vendor's list coverage and update timing are documented, and that the two-business-day reporting clock is built into the MLRO's procedure, working alongside the client's compliance adviser. We screen our own corporate service clients against the same UN and UAE lists, which keeps the KYC and UBO files we hold for clients ready for their regulated counterparties.
| Amended by | CMA Notice No. 1 of 2025 |
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