UAE

Global sanctions guide

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  1. Does the UAE have a sanctions regime in place?

The UAE does not publicise what sanctions are in force, but according to the UAE authorities, EU, UN, and US sanctions will be enforced on an ad hoc basis upon the issuance of internal directives.

  1. Does the UAE implement UN sanctions?

Yes, but these are implemented on an ad hoc basis.

  1. Does the UAE implement an autonomous sanctions regime?

There is no publicly available information according to which transactions with specific countries or entities are prohibited.

  1. What is the nature of the sanctions regime in the UAE?

The UAE implements sanctions imposed by the UN on an ad hoc basis, upon the issuance of internal directives. Specifically, the Ministry of Interior has confirmed implementation of UN sanctions concerning Somalia, Iran and North Korea.

The UAE has also reported to UN sanctions committees with regard to its implementation of UN sanctions targeting Libya, Sudan, Iran and North Korea, for instance by outlining the practical measures in place in the UAE for implementation of the relevant UNSC resolutions or by stating more generally its commitment to implementing the relevant UNSC resolutions.

Further, US and EU sanctions may also be adopted on an ad hoc basis. This may occur further to normal requests transmitted to the customs authorities or other relevant law enforcement authorities and upon examination of the circumstances and justifications advanced in support of the request.

Finally, although the GCC states recognised that total elimination of the Arab League’s boycott of Israel is a necessary step for peace and economic development in the region in 1996, the boycott of Israel may still be enforced in certain circumstances.

  1. Does the UAE maintain a list of sanctioned individuals and entities?

Whilst it is understood that there is a list of sanctioned individuals and entities, this list is only circulated internally amongst the UAE authorities. It is however thought to include sanctions against Iran, South Korea, and Somalia with regards to nuclear, chemical, and biological weapons, and weapons of mass destruction. In addition, dealings with specific persons and terrorist organisations are prohibited.

  1. Are there any other lists related to sanctions?

No.

  1. Does the UAE have a licensing or authorisation system in place?

No.

  1. What are the consequences for a breach of sanctions in the UAE?

Information regarding the UAE sanctions regime is not readily available. However, given that a sanctions regime is in place, the provisions relating to the general import and export of prohibited goods will be applied to breaches of sanctions, to the extent that they involve similar trade measures.

With regard to the breach of export control rules, the potential penalties for export of export-controlled items without a licence comprise the following:

  • at least 1 year’s imprisonment
  • a fine of at least Emirati Dirham 50,000 but no more than Emirati Dirham 500,000

The fine is doubled in instances of repeated offences and the goods may also be confiscated.

In addition, where the action in question also constitutes a particular crime, for example the funding of a terrorist organisation, criminal penalties may also be imposed.

  1. Who are the relevant regulators in the UAE and what are their contact details?

The Federal Customs Authority oversees customs policies and legislation, promotes trade and combats fraud and smuggling.

Ministry of Interior and Federal Customs Authority
Federal Customs Authority,
Ministry of Finance Building ,
2nd Floor, Fatima Bint Mubarak St,
Abu Dhabi, United Arab Emirates

E: services@customs.ae

Abu Dhabi
T: (+971) 2697 9700
F: +971 2673 5201
P.O. Box: 35000

Dubai
T: (+971) 4311 9900
F: (+971) 4393 0446

Contributor law firm

Eversheds LLP, Emaar Square Building 4 Level 7, Unit 702, Downtown Dubai, PO Box 74980, United Arab Emirates