The Dubai Financial Services Authority (DFSA) has published a thematic review on how insurance and reinsurance firms in the Dubai International Financial Centre (DIFC) comply with targeted financial sanctions (TFS) obligations. The DFSA found broadly positive levels of awareness and senior management engagement, with most improvement needs concentrated in documented control frameworks and refinements to risk assessment methodologies rather than day-to-day screening execution. The review covered all authorised insurance-sector firms in the DIFC as at 31 December 2023, with a sample of 19 firms selected for deeper engagement, and assessed screening practices, governance and oversight, notifications, record keeping, training, and independent review. Key required enhancements include more explicit Business and Customer Risk Assessments that document jurisdiction risk factors (including exposure to FATF grey-listed jurisdictions) and underlying insured risk; policies, procedures and training materials that clearly reference all UAE TFS obligations and related reporting requirements; more granular management information on screening and alert handling beyond exception reporting; completion and documentation of gap analyses; accessible local records of screening outcomes; assurance checks over screening provider coverage and inclusion of all relevant parties in screening; and audits on a regular basis as required under AML Rule 9.4. Sampled firms received individual feedback and, where applicable, remedial actions and timelines bilaterally. The DFSA also expects firms that did not complete a self-review following the UAE Supervisory Authority Sub-Committee’s May 2023 TFS thematic review to do so, record it as completed, and notify the DFSA of any identified gaps.

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