The UAE Executive Office for Control & Non-Proliferation (EOCN) and Its Link to AML Compliance

Introduction

This post is a general introduction to the UAE’s EOCN, the UAE office for control & non-proliferation. The UAE has positioned itself as a leading international hub for trade, logistics, and finance. With this comes a heightened responsibility to protect its economy from being exploited for weapons of mass destruction (WMD) proliferation, terrorism financing, and money laundering.

Two frameworks work hand-in-hand to achieve this:

• The Executive Office for Control & Non-Proliferation (EOCN), established under Cabinet Resolution No. 15 of 2022

• The UAE’s Anti-Money Laundering and Counter-Terrorist Financing (AML/CFT) regime under Federal Decree-Law No. 20 of 2018

Together, they form a dual compliance regime that businesses in the UAE must understand and implement.

What Is the EOCN?

The EOCN is the UAE’s federal authority responsible for:

• Implementing non-proliferation controls and managing permits for strategic goods

• Supervising the UAE’s compliance with UN Security Council (UNSC) resolutions

• Coordinating inspections and enforcement across customs and free zones

• Overseeing the UAE sanctions regime relating to proliferation financing

It is the UAE’s “competent authority” for enforcing Federal Decree-Law No. 43 of 2021 on Goods Subject to Non-Proliferation, supported by Cabinet Resolution No. 97 of 2024, which sets out detailed licensing and inspection procedures.

The AML/CFT Regime and Proliferation Financing

Separately, the UAE’s AML/CFT system is designed to prevent and detect:

• Money laundering

• Terrorist financing

• Proliferation financing (financial support for WMD programs)

The Executive Office of AML/CFT coordinates national AML efforts, supported by the UAE Financial Intelligence Unit (FIU) and financial regulators such as the Central Bank and the Ministry of Economy.

Notably, proliferation financing is explicitly recognized as an AML offence in line with FATF (Financial Action Task Force) standards.

Where EOCN and AML Meet

The link between EOCN and AML lies in targeted financial sanctions (TFS) and proliferation financing.

• The EOCN publishes and administers the UAE’s sanctions lists, implementing UNSC resolutions against states like North Korea and Iran.

• Banks, financial institutions, and businesses must screen clients, transactions, and end-users against these lists under their AML obligations.

• When a match or suspicion arises, entities must freeze assets immediately and file a Suspicious Activity Report (SAR) with the FIU.

In other words:

• EOCN is the technical regulator for goods, permits, and sanctions.

• AML authorities are the financial watchdogs ensuring funds and transactions are not linked to proliferation.

Both frameworks converge on the obligation of businesses to prevent their operations, supply chains, and financing channels from contributing to WMD proliferation or terrorism.

Compliance Impact for UAE Businesses

Businesses engaged in manufacturing, trading, logistics, or finance face dual responsibilities:

1. Export Control (EOCN compliance)

   • Classify goods against the national control list (strategic goods, chemicals, armoured vehicles).

   • Secure permits for import, export, re-export, transit, or brokering.

   • Maintain records for at least five years.

   • Cooperate with inspections and enforcement.

2. AML/CFT Compliance

   • Screen customers, suppliers, and counterparties against EOCN/UN sanctions lists.

   • Monitor trade finance and unusual transactions for potential proliferation financing.

   • File SARs to the FIU when suspicious activity is detected.

   • Train staff on AML and sanctions compliance.

Practical Guidance on UAE’s EOCN

To stay compliant, UAE companies should:

• Integrate EOCN controls into AML frameworks – sanctions screening and export controls must work together.

• Implement a compliance program covering both goods classification and financial monitoring.

• Engage in “catch-all” vigilance – linked to suspicious proliferation activity.

• Prepare for inspections – both EOCN and AML regulators can request data, records, and explanations. They do regularly.

Conclusion to UAE’s EOCN

The establishment of the EOCN reflects the UAE’s determination to align its trade system with international security and FATF standards. For businesses, this means compliance is not limited to trade permits or financial reporting — it is a joined-up obligation that spans both export control and AML regimes.

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*The information on this page is not intended to be legal advice. This article is intended to provide an initial introduction to the key aspects of compliance in the UAE.