The UAE does not publicize 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.
Does the UAE implement UN sanctions?
Yes, but these are implemented on an ad hoc basis.
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.
Since 2017, certain sanctions and restrictive measures have also been imposed against the state of Qatar, its government and certain Qatari companies and citizens. This includes the withdrawal of air and land links, restrictions in respect of some lending activities and restrictions in respect of the exportation of some products and the processing of certain payments in Qatari riyals.
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 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 recognized 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.
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 organizations are prohibited.
Are there any other lists related to sanctions?
Does the UAE have a licensing or authorization system in place?
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 license comprise the following:
at least one year’s imprisonment
a fine of at least Emirati Dirham 50,000 (approximately USD 13,610) but no more than Emirati Dirham 500,000 (approximately USD 136,100).
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 organization, criminal penalties may also be imposed.
Who are the relevant regulators in the UAE and what are their contact details?
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
Eversheds Sutherland is the name and brand under which the members of Eversheds Sutherland Limited (Eversheds Sutherland (International) LLP and Eversheds Sutherland (US) LLP) and their respective controlled, managed and affiliated firms and the members of Eversheds Sutherland (Europe) Limited (each an "Eversheds Sutherland Entity" and together the "Eversheds Sutherland Entities") provide legal or other services to clients around the world. Eversheds Sutherland Entities are constituted and regulated in accordance with relevant local regulatory and legal requirements and operate in accordance with their locally registered names. The use of the name Eversheds Sutherland, is for description purposes only and does not imply that the Eversheds Sutherland Entities are in a partnership or are part of a global LLP. The responsibility for the provision of services to the client is defined in the terms of engagement between the instructed firm and the client.