The AML-CFT Law and AML-CFT Decision require insurance operators to promptly apply directives issued by the Competent Authorities of the UAE for implementing the decisions issued by the United Nations Security Council (“UNSC”) under Chapter VII of the Charter of the United Nations (“UN”). In furtherance of this requirement, the Cabinet Decision No. (74) of 2020 sets out the legislative and regulatory framework regarding the Targeted Financial Sanctions (“TFS”), including the Local Terrorist List and the UN Consolidated List. As per Cabinet Decision 74 and in particular its Article 15, all insurance operators without any exception, are obliged to apply policies, procedures and controls to implement TFS to those sanctioned and designated in the Local Terrorist List and the UN Consolidated List.

For more information and details on their obligations in relation to their sanctions obligations, insurance operators should consult the Executive Office for Control and Non-Proliferation (former Executive Office of the Committee for Goods and Materials Subjected to Import and Export Control‘s – referred to as the Executive Office) “Guidance on Targeted Financial Sanctions for Financial Institutions and designated non-financial business and professions”¹³; the CBUAE’s Guidance for Licensed Financial Institutions on the Implementation of Targeted Financial Sanctions as well as the CBUAE’s Guidance for Licensed Financial institutions on Transaction Monitoring Screening and Sanctions screening and any of their amendments or updates thereof. Insurance operators should also consult the CBUAE’s and the Executive Office’s websites as updated from time to time, and refer to the Executive Office’s list of Frequently Asked Questions (FAQ) for the insurance sector.

¹³ Available at: https://www.uaeiec.gov.ae/en-us/un-page.