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Cabinet Resolution No. 97 of 2024 (the Executive Regulation) implements Federal Decree-Law No. 43 of 2021 ("On the Commodities Subject to Non-Proliferation"), which is the UAE's primary horizontal dual-use export control statute. The Executive Regulation does three things:
1. Defines the categories of controlled commodities and their scope — Strategic Commodities and Chemical Substances (items with civilian/military dual use or capable of contributing to WMD proliferation; substances harmful to public safety, health, environment, natural resources, or national security); and National Controlled Commodities (armoured civilian vehicles, autonomous equipment, civil security vehicles). 2. Empowers the Executive Office for Control & Non-Proliferation (EOCN) to maintain the National Control List, designate prohibited and restricted items, and issue export, transit, and re-export permits — within a 20-working-day decision window from the date of complete application. 3. Enforces the regime via fines (AED 100,000–1,000,000 ≈ USD 27k–272k for false-information offences), commodity seizure, permit cancellation, suspension/dissolution of offending entities, and whistleblower rewards; imprisonment is reserved for state-security violations under the parent Federal Decree-Law.
The Control List itself follows the multilateral-regime architecture (NSG, AG, MTCR, Wassenaar) and covers nuclear materials, chemical precursors, electronics and telecommunications, sensors and lasers, navigation/avionics, marine and aerospace equipment, propulsion systems, and chemical-weapons precursors — the same product perimeter as the EU dual-use list and the US CCL.
advanced AI-compute outbound flows is administered. G42's authorisation to procure US advanced AI chips (under the May-2024 Microsoft equity arrangement and subsequent US BIS validated-end-user discussions) ultimately flows through EOCN permits issued under this regime — not through US BIS authority alone. The Executive Regulation is the host-country instrument that pairs with US extraterritorial controls.
type — prior AE filings (Operation 300bn 2021-03-22, Industrial Resilience Fund 2026-04-26) are industrial-strategy and investment-policy, not dual-use trade control. Closes a structural coverage gap.
regulation for a sovereign-state dual-use regime), (ii) scope (entire AI/ semiconductor/aerospace/chemicals stack), and (iii) live-deal relevance (G42 / advanced-chip licensing).
by destination country and end-use category would be a leading indicator of whether the UAE regime is tightening or relaxing in practice (parallel to the Japanese/Dutch licence-approval-rate watch under the trilateral perimeter).
destination-specific catch-all controls or "non-listed item" residual authority equivalent to the EU dual-use Article 4 / US "is informed" mechanism.
Sep 2025) — adjacent proliferation-financing instrument; future filing if enforcement actions surface.