· Jurisdiction Briefing

UN sanctions across the six: the domestic lists and clocks behind the UN list

Each of our six jurisdictions implements UN targeted financial sanctions, and each also applies a domestic list alongside the UN list: for DIFC and ADGM, the UAE's federal one. Which list, which clock and who you tell afterwards are set locally. This is part…

Illustration for “UN sanctions across the six: the domestic lists and clocks behind the UN list”

Each of our six jurisdictions implements UN targeted financial sanctions, and each also applies a domestic list alongside the UN list: for DIFC and ADGM, the UAE’s federal one. Which list, which clock and who you tell afterwards are set locally. This is part 2 of Across the Six.

Who does what

JurisdictionKey body and instrumentDomestic listFreeze clockAfter a freeze
UAE (federal)Executive Office for Control & Non-Proliferation, Cabinet Decision No. 74 of 2020UAE Local Terrorist List, issued by the Cabinet“Without delay”: within 24 hours of the listing decision by the UN Security Council, the Sanctions Committee or the CabinetConfirmed or Partial Name Match Report to the Executive Office and your supervisor via goAML, within five business days
DIFCDFSA, whose AML Module points firms to Article 21 of Cabinet Decision 74 of 2020Federal listsFederal ruleFederal rule
ADGMFSRA, whose AML Rulebook names the Executive Office as the UAE focal point for targeted financial sanctionsFederal listsFederal ruleFederal rule, plus an immediate notification to the FSRA of a possible sanctions contravention
Saudi ArabiaSAMA’s Rules for the Implementation of Targeted Financial Sanctions, for SAMA-supervised financial institutionsNational sanctions lists, updated from the Permanent Counter Terrorism Committee and a Ministry of Foreign Affairs committee“Without delay”: within hours of designationNotify SAMA by email
QatarNational Counter-Terrorism Committee; Public Prosecutor Decision No. 1 of 2020Sanctions List, including persons designated by the Public ProsecutorNational designations: within 12 hours of announcement. UN designations: no later than 24 hoursFirst report to your supervisor within 48 hours of the designation order, a second within 30 days
MauritiusNational Sanctions Secretariat, United Nations (Financial Prohibitions, Arms Embargo and Travel Ban) Sanctions Act 2019List of designated parties kept by the SecretariatDuties apply forthwith, not later than 24 hours after the UN list or the Secretariat’s public noticeReport to the Secretariat and your supervisor, including when no funds are found
MoroccoNational Commission for UN sanctions (CNASNU), chaired by the Ministry of Justice; Decree 2-21-484Local list of sanctioned persons and entitiesAs described by MENAFATF in May 2022: freeze upon publication on the commission’s websiteAs described by MENAFATF in May 2022: report to the commission within 48 hours of the decision confirming the freeze

Five things the table hides

DIFC and ADGM firms work to the federal instrument. Both centres have their own AML rulebooks, but on targeted financial sanctions both point firms to Article 21 of Cabinet Decision 74 of 2020. The FSRA’s rulebook lists what that article requires, including freezing without delay and notifying the authorities of confirmed or partial matches.

Saudi Arabia removed the usual excuses in writing. SAMA issued its rules by circular on 7 December 2025, and its rulebook shows them as in force. Once a match is confirmed, the freeze may not wait for an internal committee, a legal review or senior-management approval.

Qatar runs two clocks. Under the Public Prosecutor’s decision, a national designation must be implemented within 12 hours of announcement. A UN designation must be frozen no later than 24 hours after the UN listing, without waiting for a national order.

Mauritius asks for a report even when you hold nothing. Every reporting person must check its customers against a new designation or listing, and report to the National Sanctions Secretariat whether funds are identified or not, with a copy to its supervisory authority. As amended by Act No. 3 of 2026, the Act says these duties apply forthwith and no later than 24 hours after the UN list or the Secretariat’s public notice.

Morocco’s clock, as MENAFATF described it, starts on the commission’s website. MENAFATF’s May 2022 follow-up report found that the obligation to freeze runs from publication on the commission’s site, and re-rated Morocco from partially to largely compliant on Recommendation 6. We could not confirm from a Moroccan official document for this briefing whether that mechanism has changed since.

What this means

A screening engine fed only by the UN consolidated list would miss the domestic designations in each of these regimes. The clocks are short enough that a slow list refresh can use up most of the time allowed.

Three things worth doing this week

  1. List your list sources, one row per jurisdiction. For each, write down where the domestic list comes from and how it reaches your screening engine. Any row that says “the vendor has it” needs evidence.
  2. Time a designation end to end. Pick a recent local designation and trace when it was published, when it reached your system and when it would have produced an alert. Compare that with the local clock: 24 hours in the UAE and Mauritius, 12 hours for a Qatari national designation.
  3. Write the report that follows the freeze. goAML in the UAE, an email to SAMA in Saudi Arabia, the 48-hour first report in Qatar, a report in Mauritius even when nothing is found. Have a template for each before you need it.

Sources

This article draws on the following sources. Follow the links for the original text.

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