Best Sanctions & Export Controls Lawyers in United Arab Emirates

About Sanctions & Export Controls Law in United Arab Emirates

Sanctions and export controls in the United Arab Emirates (UAE) comprise laws, regulations, and provisions governing the movement of goods, technology, services, and financial transactions across national borders. These regulations serve to uphold international obligations, protect national security, and prevent activities that may violate international sanctions or involve sensitive goods subject to control. The UAE actively implements international sanctions, including United Nations Security Council Resolutions, while also maintaining its own set of export controls tailored to protect national interests.

Why You May Need a Lawyer

Individuals and businesses often encounter complex issues in the area of sanctions and export controls. Common situations where legal assistance is critical include:

• Engaging in cross-border trade that may involve sanctioned countries, entities, or individuals.
• Seeking clarification on compliance with evolving UAE and international sanctions regulations.
• Launching a business that deals with dual-use or military-grade items, which may require licensing or face export restrictions.
• Facing investigations or penalties from authorities for potential violations of export control laws.
• Needing to conduct due diligence on potential partners or clients to avoid inadvertently breaching sanctions.
• Responding to requests from banks for detailed information about transactions under scrutiny for sanctions compliance.

Local Laws Overview

The UAE enforces comprehensive sanctions and export control regulations through a combination of federal laws, cabinet decisions, and ministerial resolutions. Key aspects include:

• United Nations Obligations: The UAE implements all binding UN Security Council sanctions, which may involve arms embargoes, asset freezes, and travel bans.
• Federal Law No. 13 of 2007: This law governs the import and export of strategic goods and establishes the Committee for Goods and Material Subject to Import and Export Control, which oversees the licensing and regulation process.
• Dual-Use Goods: Controls are in place for items that have both civilian and military applications. Exports of such goods typically require licensing.
• Financial Sanctions: Banks and financial institutions must screen transactions for compliance and report any suspicious activities linked to sanctioned parties.
• Customs Regulations: UAE customs authorities monitor compliance with export control regulations at ports, airports, and border crossings.
• Strict Enforcement and Penalties: Violations can result in steep fines, imprisonment, business license revocation, and asset seizures.

Frequently Asked Questions

What are sanctions and export controls?

Sanctions are legal restrictions imposed against specific countries, organizations, individuals, or sectors to achieve foreign policy, security, or human rights objectives. Export controls are regulations that restrict or require licenses for the transfer of certain goods, technologies, or services across borders, especially those that are sensitive for security or strategic reasons.

Which authorities oversee sanctions and export controls in the UAE?

The Federal Authority for Nuclear Regulation, the Ministry of Economy, the Central Bank of the UAE, and the Committee for Goods and Material Subject to Import and Export Control are some of the main regulatory bodies. Customs authorities also play a critical role.

Do I need a license to export dual-use goods from the UAE?

Yes, exporting dual-use goods, which can serve both civilian and military applications, usually requires obtaining an export license from the relevant regulatory authority in the UAE.

What are the penalties for breaching sanctions or export control laws?

Penalties for non-compliance can include hefty fines, imprisonment, confiscation of goods, business license suspension, and asset freezing.

If a company is based in a UAE free zone, are they exempt from sanctions regulations?

No, all entities operating in the UAE, including those in free zones, must comply with local and international sanctions and export control regulations.

How can a business check if a client or partner is subject to sanctions?

Businesses are expected to conduct due diligence by checking against official sanction lists published by UAE authorities and relevant international bodies. Many businesses use screening software and legal counsel for complex cases.

Are there any sectors that are particularly affected by sanctions and export controls?

Yes, sectors dealing with strategic technologies, military and defense goods, chemicals, advanced manufacturing, finance, and international logistics face heightened scrutiny and regulatory obligations.

Can an individual be held liable for an export control violation, or is it only the company?

Both individuals and companies can be held liable under UAE law. Directors, managers, and personnel involved in violations may face prosecution and personal penalties.

How do UAE sanctions compare to those imposed by other countries?

The UAE generally follows UN Security Council resolutions but can also impose its own restrictions. Unlike sanctions imposed by the US, UK, or EU, which may have extra-territorial reach, UAE sanctions directly affect activities within the UAE’s jurisdiction.

What should I do if I suspect a possible sanctions or export controls violation?

Immediately seek legal counsel to assess the situation and propose corrective action. It is important to cooperate with authorities where required and to avoid concealing information.

Additional Resources

If you need further information or assistance, the following are key resources and organizations in the UAE:

• Ministry of Economy - Committee for Commodities Subject to Import and Export Control Division
• Federal Customs Authority
• Central Bank of the UAE - For financial sanctions compliance
• Federal Authority for Nuclear Regulation - For strategic and dual-use goods
• Free Zone Authorities’ Compliance Departments
• Embassies and trade missions for country-specific guidance

Next Steps

If you believe you may need legal advice or representation regarding sanctions and export controls in the UAE, consider the following steps:

• Gather all relevant documents and information about your activities, transactions, or goods in question.
• Contact a legal professional with expertise in UAE sanctions and export controls.
• Request a case assessment to clarify your compliance requirements and risks.
• Implement recommended compliance policies and internal controls to mitigate risk.
• Regularly review and update your processes in line with changing laws and international obligations.

Early and informed legal guidance can help you avoid costly penalties and protect your business interests while ensuring full compliance with UAE law.