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TFS: FI AND DNFBPs OBLIGATIONS
The Executive Office is one of the authorities responsible for overseeing the administration and implementation of the UAE’s export controls regime as well as targeted financial sanctions. In this respect, the Guidance articulates significant obligations that, although intended mainly for financial institutions and DNFBPs, extend requirements applicable to all legal and natural persons in the UAE. Specifically, an all-natural and legal person in the UAE must:
  • Register
The Executive Office of the Committee for Goods Subject to Import and Export Control to receive automated updates to the lists.
  • Screening
Conduct screening on existing, new, and potential clients to verify any positive names matched with any designated person (Entity or Individual).
  • Implement TFSTargeted financial sanctions include both asset freezing and prohibitions to prevent funds or other assets from being made available, directly or indirectly, for the benefit of individuals, entities, groups, or organizations who are sanctioned.Types of financial sanctions:
    • Asset freezing
    Freezing is the prohibition to transfer, convert, dispose, or move any funds or other assets that are owned or controlled by listed individuals, groups, or entities.
  • Prohibition to offer funds and services:       This means the prohibition to provide funds to, or render financial services or other services related to any listed individual, group, or entity.
Internal Control
  • Must have appropriate internal controls to ensure compliance with the most recent publication of targeted financial sanctions of the UNSC Consolidated lists and the Local Lists.
  • Internal controls and procedures to ensure compliance with the obligations arising from Cabinet Resolution 74/2020.
  • Policies and procedures that prohibit staff from, directly or indirectly, informing the customer or any third party that freezing action or any Other Measures are going to be implemented as per provisions of Cabinet Resolution 74/2020.
 

Source: Committee for Goods Subject to Import and Export Control