A new client wants to sign up — do I need to screen them against sanctions lists first?

Yes, and this is not an optional step. Under Cabinet Resolution No. 74 of 2020 on the implementation of targeted financial sanctions, any regulated entity — including DNFBPs such as accounting and advisory firms — must screen a prospective client against the UN Consolidated List and the UAE Local Terrorist List issued by the Executive Office for Control and Non-Proliferation before accepting them, and continue screening existing clients on an ongoing basis, before processing any transaction. The screening has to cover beneficial owners, directors, and power-of-attorney holders too, not just the person sitting across the table.

If screening turns up a confirmed match, the required action is immediate: freeze any related funds or assets "without delay" and report to the Executive Office and the relevant supervisory authority via the goAML platform within a short, defined window. If the match is only partial or uncertain, the practical step is to suspend the relationship or decline onboarding until identity is confirmed with sufficient documentation. Screening records must also be kept for a minimum of five years. RASEEKH helps clients set up a practical, documented screening process rather than scrambling for one at inspection time.