The United Arab Emirates continues to strengthen its position as a global leader in financial integrity and international security compliance. A significant recent development is Cabinet Resolution No. (156) of 2025 Regarding the Schedule of Goods Subject to Control and Non-Proliferation, issued on 4 November 2025 and effective from 15 November 2025.
This resolution approves an updated Schedule of Goods Subject to Control and Non-Proliferation, building on Federal Decree-Law No. (43) of 2021 concerning goods subject to non-proliferation. It empowers the Minister of Foreign Affairs to amend the schedule as needed, ensuring the UAE remains agile in addressing emerging threats.
Why This Matters for UAE AML Compliance
In the context of the UAE’s robust Anti-Money Laundering (AML), Combating the Financing of Terrorism (CFT), and Countering the Financing of Proliferation (CPF) framework, particularly under the new Federal Decree-Law No. (10) of 2025 and its Executive Regulations (Cabinet Resolution No. 134 of 2025), this schedule plays a critical role.
Proliferation financing (PF) involves the provision of funds or financial services that could contribute to the development or acquisition of weapons of mass destruction or related delivery systems. Businesses must integrate PF risk into their Enterprise-Wide Risk Assessment (EWRA), customer due diligence (CDD), and ongoing monitoring processes.
Entities involved in trade, manufacturing, logistics, or financial services related to dual-use goods, chemicals, electronics, aerospace, or other listed items must exercise heightened vigilance to avoid facilitating proliferation financing, even unwittingly.
Why is there a list of Goods Subject to Non-Proliferation?
To understand the significance of this resolution, it helps to revisit the core concepts underpinning it:
- WMD (Weapons of Mass Destruction) proliferation encompasses the manufacture, acquisition, development, transfer, transport, stockpiling, or use of nuclear, chemical, or biological weapons, their delivery systems, and related materials. This includes dual-use goods and technologies, meaning items with legitimate civilian applications that could also contribute to weapons development if diverted.
- Proliferation financing refers to raising, moving, or making available funds or economic resources, in whole or in part, to persons or entities engaged in WMD proliferation activities. Proliferation financing risk, as defined under FATF Recommendation 7, relates specifically to the potential breach or evasion of targeted financial sanctions under relevant UN Security Council Resolutions.
A critical development under the new Federal Decree-Law No. (10) of 2025 is that proliferation financing is now designated as a predicate offence to money laundering, elevating it from a risk indicator under previous guidelines to a standalone criminal offence equivalent in weight to money laundering itself. This is a material shift in legal exposure for any business involved in the trade, transfer, or financing of dual-use goods.
Accordingly, all Designated Non-Financial Businesses and Professions (DNFBPs), Financial Institutions (FIs), and Virtual Asset Service Providers (VASPs) must now assess whether goods or technologies handled by their customers appear on the controlled goods schedule. Failure to do so is no longer merely a compliance gap; it carries direct criminal liability.
Practical Implications for Businesses
- Update Policies and Procedures: Incorporate PF risks linked to the new schedule into your AML/CFT/CPF manual.
- Transaction Screening: Implement robust screening for counterparties and goods against the control list. i.e. now know whether the use of the goods/technologies provided by your customer is under Dual-Use or not.
3.Training: Ensure staff, especially compliance officers and relationship managers, receive regular training on proliferation red flags.
4.Record-Keeping: Maintain comprehensive records of due diligence for transactions involving controlled goods, as required under UAE regulations.
5.Licensing and Approvals: Seek necessary permits from relevant authorities (e.g., Executive Office for Control & Non-Proliferation) for handling listed items.
Failure to comply can result in severe penalties, including significant fines, business restrictions, or criminal liability under the broader AML framework.
Frequently Asked Questions (FAQs)
1: What is the Schedule of Goods Subject to Control and Non-Proliferation?
It is an approved list of commodities, technologies, software, and materials whose import, export, or transfer is regulated to prevent proliferation of weapons of mass destruction and related risks.
2: How does this resolution connect to UAE AML laws?
It supports the CPF pillar of the UAE’s AML/CFT/CPF regime by identifying goods that could be misused. Businesses must assess PF risks when dealing with these goods or related parties.
3: Who needs to comply?
All regulated entities under UAE AML laws, particularly those in trade finance, customs brokerage, manufacturing, shipping, and financial services, should review their exposure.
4: Do I need to update my EWRA?
Yes. Include proliferation risks from the schedule and apply a risk-based approach to mitigation measures.
5: Where can I access the full schedule?
Refer to the official text on the UAE Legislation portal and consult the Executive Office for Control & Non-Proliferation for guidance.
How Jitendra Chartered Accountants Can Help You
Navigating the evolving UAE AML/CFT/CPF landscape, including non-proliferation controls, requires expert guidance to ensure full compliance while supporting business growth.
At Jitendra Chartered Accountants, our team of experienced professionals offers comprehensive services, including:
- AML/CFT/CPF compliance audits and gap assessments.
- Development and implementation of tailored policies, procedures, and risk assessments.
- Training programmes on PF and sanctions compliance.
- Assistance with goAML registration and suspicious transaction reporting.
- Ongoing advisory support for DNFBPs, VASPs, and other entities.
Partner with us to transform regulatory obligations into a competitive advantage. Contact Jitendra Chartered Accountants today for a consultation and ensure your business remains compliant, resilient, and future-ready in the UAE.