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 and 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 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

The UAE’s AML/CFT framework is designed to prevent and detect:

• Money laundering
• Terrorist financing
• Proliferation financing (financial support for WMD programmes)

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.

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

Where EOCN and AML Meet

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

• The EOCN administers the UAE’s sanctions lists, implementing UN Security Council resolutions against jurisdictions such as North Korea and Iran.
• Banks, financial institutions, and businesses must screen clients, transactions, and end users against these lists as part of their AML obligations.
• Where a match or suspicion arises, entities must freeze assets immediately and file a Suspicious Activity Report (SAR) with the FIU.

In practical terms:

• 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 involved in manufacturing, trading, logistics, or finance face dual responsibilities:

1. Export control (EOCN compliance)

   • Classify goods against the national control list.
   • Obtain permits for import, export, re-export, transit, or brokering.
   • Maintain records for at least five years.
   • Cooperate with inspections and enforcement actions.

2. AML/CFT compliance

   • Screen customers, suppliers, and counterparties against sanctions lists.
   • Monitor trade finance and transactions for proliferation risk.
   • Submit SARs to the FIU where required.
   • Train staff on AML and sanctions obligations.

Practical Guidance on the UAE’s EOCN

To remain compliant, UAE companies should:

• Integrate EOCN controls into AML frameworks so sanctions screening and export controls operate together.
• Implement a unified compliance programme covering goods classification and financial monitoring.
• Apply “catch-all” vigilance where transactions or end uses raise proliferation concerns.
• Prepare for inspections by both EOCN and AML regulators, who may request records and explanations.

Conclusion

The establishment of the EOCN demonstrates the UAE’s commitment to aligning its trade and financial systems with international security and FATF standards. For businesses, compliance is no longer limited to trade permits or financial reporting; it is a joined-up obligation spanning both export control and AML regimes.

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We hope this publication is helpful and remain available for any questions of general application.

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