Cabinet Decision No. 156/2025 adopted a new Schedule of Goods Subject to Control and Non-Proliferation on 4 November 2025 and expressly abrogated Cabinet Decision No. 50/2020. The parent statute changed earlier and more quietly: Federal Decree-Law No. 43/2021 declared Federal Law No. 13/2007 null and void with effect from 2 January 2022. Compliance manuals and customer risk models still built on the 2007 law and the old strategic goods list are pointing at instruments that no longer exist.
Who should read this
If a compliance manual, CPF risk assessment or customer risk model still names Federal Law 13/2007 or a Ministry of Economy strategic goods list, it is citing a repealed statute and a superseded schedule, and the mapping exercise behind it needs to be redone against Cabinet Decision 156/2025.
Directly affected
Key facts
- Cabinet Decision No. 156/2025 was issued on 4 November 2025, published in Official Gazette issue 811 at page 183, and came into force the day after publication (Article 4).
- Article 3 of the Decision abrogates Cabinet Decision No. 50/2020 on the schedule of strategic goods annexed to Federal Law No. 13/2007, together with any inconsistent provision.
- Article 30(1) of Federal Decree-Law No. 43/2021 on the Commodities Subject to Non-Proliferation declares Federal Law No. 13/2007 null and void; Article 31 set the effective date at 2 January 2022.
- The schedule runs to eleven categories — from nuclear materials and electronics to computers, information security, sensors and lasers, marine and aerospace — and implements the MTCR, the Nuclear Suppliers Group, the Wassenaar Arrangement, the Australia Group and the CWC.
- Article 2 of the Decision lets the Minister of Foreign Affairs amend the schedule by addition, deletion or substitution, so the list moves without a new Cabinet Decision each time.
- Article 2 of Decree-Law 43/2021 applies the regime to all territories of the State, free zones included, which removes the free-zone carve-out some structures were built around.
What this means for you
Two provisions do most of the work for clients, and neither is about physical cargo. Article 9(1)(b) of Decree-Law 43/2021 makes it an offence to deliver, forward, publish, disclose or share any document or device related to a controlled commodity without a permit. On its terms that reaches an emailed drawing, a design file in a shared folder, a specification handed to a foreign engineer, and a technical paper put online — intangible transfers that never cross a border in the customs sense and never appear on a bill of lading. Article 11 then captures brokerage and negotiation where a person merely has "good reasons to suspect" that a contract may move controlled goods, documents or technology between states. That is a suspicion standard, not a knowledge standard, and it binds intermediaries, agents and advisers who never take title. The consequences are not ordinary regulatory consequences: Article 18(2) deems these offences crimes against State security, Article 18 carries imprisonment of at least one year with fines from AED 100,000 to AED 1 million, Article 18(5) requires the court to deport a convicted foreigner after sentence, and Article 20 exposes the company itself to AED 200,000 to AED 2 million with dissolution or closure available. Article 14 also lets the competent authority seize goods that are not on the schedule at all where it suspects a controlled end use or a listed end user.
Amends / replaces: Cabinet Decision No. 156/2025 abrogates Cabinet Decision No. 50/2020. Federal Decree-Law No. 43/2021 repealed Federal Law No. 13/2007 with effect from 2 January 2022.
Directly affected: Re-export and trading companies, free zone entities, logistics and freight forwarders, semiconductor and electronics distributors, engineering and technology firms transferring technical data abroad, and banks and DNFBPs running counter-proliferation financing programmes
Effective date: 5 November 2025 (the day after publication in Official Gazette issue 811)
Action items
- Re-run the dual-use classification exercise against the eleven categories of the schedule annexed to Cabinet Decision 156/2025, rather than against the EU dual-use annexes alone
- Replace every reference to Federal Law 13/2007 in policies, manuals, training decks and client questionnaires with Federal Decree-Law 43/2021, and name the current competent authority
- Put a permit check in front of intangible transfers — engineering drawings, design files, specifications and source code sent to colleagues or customers outside the UAE
- Extend screening to brokerage and agency work, because Article 11 bites on "good reasons to suspect" rather than on knowledge
- Confirm that free zone and offshore entities in the group are inside scope, since Article 2 applies the Decree-Law to all territories of the State including free zones
- Diarise a periodic check of the schedule, which the Minister of Foreign Affairs may amend by addition, deletion or substitution without a fresh Cabinet Decision
Litigation impact
Because Article 18(2) characterises these as crimes against State security, an investigation is unlikely to stay in a regulatory channel where it can be settled administratively, and Article 23 gives designated employees of the competent authority the capacity of judicial officers when recording violations. Article 8 compounds the timing problem: decisions of the competent authority must be appealed within seven days of notification, and a court will not entertain an action to annul a decision that has not first been appealed. Article 22 offers a narrow route the other way, waiving penalties for a person who reports before an offence is attempted where the report leads to detection or prevention, and allowing mitigation for cooperation afterwards.
Source
Federal Decree-Law No. 43/2021 (official text) and Cabinet Decision No. 156/2025, Official Gazette issue 811
https://uaelegislation.gov.ae/en/legislations/1961
Original-source date: 4 November 2025 · Captured: 2026-10-31T10:24:02+04:00
This update is generated from a public regulator publication and reviewed under the firm's automated editorial quality gate. General information only — it does not constitute legal advice. For advice on a specific matter, please contact us. Last updated: 31 October 2026.