The RAK ICC Sanctions Policy Questionnaire Explained

What is the RAK ICC Sanctions Policy Questionnaire?

The RAK ICC Sanctions Policy Questionnaire is a declaration a company completes to confirm that neither it nor its Related Parties is a sanctions target, and that its business will not breach or cause RAK ICC to breach applicable sanctions. It reflects RAK ICC's policy of fully complying with the sanctions laws and regulations of the United Arab Emirates, the United Nations, the United States and the European Union (including the United Kingdom), and any other such laws where applicable to its business. If you are completing one, you are formally attesting to your company's sanctions position — and getting it wrong, or letting it fall out of date, has real consequences. Fastlane handles sanctions screening and declarations as part of our UAE AML and compliance services.

The questionnaire works by asking a series of "to the best of your knowledge" questions, each answered Yes or No, with further detail required for any "Yes". Those questions probe five things: whether the company or a Related Party is itself a Sanctions Target; whether it is owned by one; whether a Sanctions Target can exercise control over it; whether it has any presence or Business Activity involving a Sanctioned Territory or a Sanctions Target; and whether any Related Party is a close family member or business partner of a Sanctions Target. It closes with a confirmation that the company's dealings through RAK ICC will not involve a sanctioned country, and with a strict duty to keep the declaration current.

What distinguishes a sanctions questionnaire from other onboarding forms is its bluntness and its consequences. Sanctions compliance is not risk-rated the way some due-diligence measures are — a genuine sanctions hit is generally a hard stop, not a matter for enhanced monitoring. The questionnaire is therefore designed to surface exposure clearly and early, so that RAK ICC can act before a prohibited relationship or transaction occurs. That is also why it reaches so far into ownership, control and family connections: sanctions evasion classically operates through exactly those indirect routes.

Who counts as a “Sanctions Target”?

A Sanctions Target is a person or entity that falls into any of three categories: those listed as a target of sanctions by the UAE, UN, US, EU or UK; those owned or controlled by, or operating as agents of, the governments of Cuba, Iran, North Korea, Syria, Russia or Venezuela; or those resident or domiciled in an Embargoed Country. It is a deliberately wide definition, because sanctions exposure is not limited to individuals who appear by name on a list.

The first limb — being listed — is the most familiar. The major authorities each maintain designation lists (for example, the US administers its lists through OFAC and the UK through OFSI), and a match against any of them makes a person a Sanctions Target for these purposes. But the second and third limbs extend well beyond named designations. The second captures entities that are government-owned, government-controlled, or acting as agents of specified governments — so an ordinary-looking commercial entity can be a Sanctions Target purely by virtue of its ownership or its role as a state agent. The questionnaire spells this out in detail for Venezuela, noting that the government of Venezuela includes the state, its political subdivisions, agencies and instrumentalities such as the Central Bank of Venezuela and PdVSA, anyone owned or controlled by them, and anyone acting on their behalf, including as part of the Maduro regime.

The third limb turns on residence or domicile in an Embargoed Country, independent of any listing or government connection. This is why nationality, residence and place of domicile of Related Parties matter so much in sanctions screening: a person can be a Sanctions Target simply by being resident or domiciled in an embargoed jurisdiction. The practical lesson is that you cannot clear a company by checking names against a list alone — you have to understand where the relevant people are based and how the entity is owned and controlled, which is exactly what the rest of the questionnaire is built to establish.

Who are your “Related Parties” for sanctions purposes?

Related Parties are the people connected to the company whose sanctions status must be checked, and the questionnaire draws the category widely: it includes, but is not limited to, shareholders, beneficial owners, key controllers (such as directors and senior managers), trustees, founders, grantors, settlors and beneficiaries. The screening obligation therefore extends across the whole cast of people who own, control or benefit from the company — not just those on the share register.

The inclusion of trustees, founders, grantors, settlors and beneficiaries is significant, because it pulls trust and foundation structures squarely into scope. In a structure where legal ownership and beneficial interest are separated — a trust, a foundation, a nominee arrangement — sanctions screening cannot stop at the visible legal owner. The person who established the structure, the person who controls it, and the people who benefit from it are all Related Parties, and each must be clear of sanctions exposure. This mirrors the logic of beneficial ownership rules generally: what matters is the reality of ownership and control, not just its legal form.

"Key controllers" is the phrase that captures the control dimension at the individual level — directors and senior managers who direct the company even where they hold no shares. Combined with the eight-part control test later in the questionnaire, this ensures that a Sanctions Target cannot escape detection simply by controlling a company without owning it. The practical task when completing the questionnaire is to list out every Related Party across all these categories and check each one, because a single unscreened controller, settlor or beneficiary is exactly the gap the definition is designed to close. Our beneficial ownership and screening support helps map and check the full set.

Which countries and territories does the questionnaire cover?

The questionnaire references a specific set of jurisdictions, and it is essential to read them as a point-in-time snapshot rather than a permanent list. As issued, the Embargoed Countries are Iran, Syria, North Korea, Cuba, Crimea, and the oblasts of Kherson, Zaporizhzhia, Donetsk and Luhansk of Ukraine; the specified governments in the ownership limb are Cuba, Iran, North Korea, Syria, Russia and Venezuela; and the closing confirmation refers to sanctioned countries as, at present, Crimea, Cuba, Iran, North Korea and Syria.

Two things follow from this. First, the lists are not perfectly uniform even within the document — the ownership limb names Russia and Venezuela among the specified governments, while the closing confirmation lists a narrower set of sanctioned countries. That is a normal feature of layered sanctions drafting, where different tests capture different things, but it underlines why you must read each question on its own terms rather than assuming a single global list applies everywhere.

Second, and more importantly, sanctions designations change frequently. Countries, territories, entities and individuals are added to and removed from the UAE, UN, US, EU and UK regimes on an ongoing basis, and a list that was accurate when a form was issued may not be current today. For that reason, completing the questionnaire honestly requires screening against live official sources at the time, not simply reading the countries printed on the form. The document captures the framework; the live lists capture the current reality, and both matter. This is one of the clearest cases where relying on a static document is a mistake, and where current professional screening earns its keep.

What does the sanctions questionnaire actually ask?

It asks a focused set of Yes/No questions, each requiring further detail for any "Yes", covering exposure through status, ownership, control, territory, business activity and personal connections. Taken together they build a complete picture of whether the company touches sanctions in any way.

The structure is cumulative and deliberate. The first question catches direct status. The second and third catch indirect exposure through ownership and control — the two classic routes by which a sanctioned person sits behind a clean-looking company. The fourth and fifth catch operational exposure, whether through physical presence in a territory or through actual business dealings, and require you to quantify how much of your business is involved. The sixth catches the human dimension: close family members and business partners of Sanctions Targets, who are common conduits for evasion.

The recurring requirement to state a percentage — of shares held by a Sanctions Target, or of Business Activity involving a Target or Territory — is a distinctive and important feature. It reflects that sanctions exposure is not always binary; the extent of an ownership interest or a trading relationship matters to the analysis, and a small percentage may be treated very differently from a controlling one. Where you answer "Yes" to any of these, a bare confirmation is not enough — you must quantify the exposure, because that figure is what allows RAK ICC to assess the risk properly.

How does the eight-part control test work?

The control question is the most sophisticated part of the questionnaire, because it recognises that a Sanctions Target can dominate a company without owning a single share. It asks whether a Sanctions Target has the ability to exercise control, and defines that ability through eight distinct routes (a to h) — any one of which is enough. Ownership is only one way to control a company; the test captures the others.

Read the routes carefully and a pattern emerges: several of them require no shareholding at all. Route (a) is about board appointment rights, which can be granted contractually to a non-shareholder. Route (c) captures voting control assembled through a shareholders' agreement rather than through owned shares. Routes (d) and (e) reach "dominant influence" — and route (e) is especially broad, catching the power to exercise dominant influence or the fact of actually exercising it, even without a formal right. Route (f) is about the right to use the company's assets; route (g) about managing it on a unified basis; and route (h) about standing behind its financial liabilities. None of these depends on the share register.

This is why the eight-part test matters so much in practice, and why answering the ownership question "No" does not end the analysis. Consider a company where a Sanctions Target holds only a minority stake — so the ownership question is genuinely "No" — but a side agreement gives that person the right to appoint most of the board and a veto over major decisions. Under routes (a) and (d), that person can exercise control, so the control question is "Yes", even though ownership is not. A form completed by looking only at the shareholding would miss this entirely. The test exists precisely to catch the arrangements — nominee structures, shareholders' agreements, management contracts, guarantees — through which real control is exercised off the register.

What is a “Sanctioned Territory” and what counts as “Business Activity”?

These two defined terms drive the operational questions, and both are drawn broadly. A company has exposure to a Sanctioned Territory if it has any presence there or conducts Business Activity involving it — and each of those terms is defined to capture far more than the obvious. Where either exists, the questionnaire requires you to state the percentage of your business involved.

Presence is defined to include a registered office, a branch, a subsidiary, operations, an address, or a principal place of business in the territory. So it is not only a head office that counts — a branch, a subsidiary, an operational footprint, or even a registered address in a Sanctioned Territory creates exposure that must be declared. Business Activity is defined even more expansively: it includes sales and purchases — whether directly or indirectly through agents or intermediaries — as well as investments and transhipments. That reach through "agents or intermediaries" is crucial, because it means you cannot avoid the question by routing dealings through a third party; indirect trade with a Sanctioned Territory is still Business Activity.

The inclusion of transhipments is a detail worth highlighting. Goods that merely pass through a Sanctioned Territory — without originating or terminating there — can constitute Business Activity, which is why the closing confirmation of the questionnaire specifically addresses goods procured from or transhipped through a sanctioned country. Supply chains that touch a sanctioned jurisdiction at any point, even in transit, are within scope. And because the questions require a percentage of Business Activity, you must be able to quantify the proportion of your dealings that involves the territory or a Sanctions Target — a "Yes" without a figure is an incomplete answer. Understanding your supply chain and counterparties at this level is part of sound financial record-keeping and controls, and it is what makes an accurate declaration possible.

What about ownership percentages and family or business-partner links?

The questionnaire treats ownership and personal connections as separate, quantifiable exposures. For ownership, if the company is owned by a Sanctions Target you must describe the position including the percentage of shares held. For personal connections, you must confirm whether any Related Party is a close family member — specifically a parent, spouse or child — or a business partner of a Sanctions Target. Both routes are common vectors for sanctions evasion, and both are screened explicitly.

The percentage requirement on ownership reflects, again, that exposure is a matter of degree. A Sanctions Target holding a small minority interest presents a different risk profile from one holding a controlling block, and the figure you provide is what lets that distinction be drawn. This is not an invitation to downplay — the obligation is to state the actual percentage accurately — but it does mean the analysis is proportionate to the real extent of the interest. Ownership that sits below control thresholds still has to be disclosed; it is simply assessed in light of its size.

The family-and-business-partner question closes a well-known gap. Sanctioned individuals frequently attempt to operate through close relatives — a spouse, a parent, a child — or through business partners who hold assets or run companies on their behalf. By asking directly whether any Related Party has such a connection, the questionnaire forces disclosure of relationships that a pure name-screen against sanctions lists would never reveal, because the relative or partner is not themselves listed. This is the human-network dimension of sanctions compliance, and it is exactly where diligent screening adds value beyond automated list-matching. Our AML and sanctions team helps identify and assess these connections as part of a full screening exercise.

Why does RAK ICC screen for sanctions, and who are the authorities?

Because compliance with international sanctions is non-negotiable, and a registry that facilitated a sanctions breach would expose itself, its agents and the UAE to serious legal and reputational harm. RAK ICC's stated policy is to comply fully with the sanctions laws and regulations of the UAE, the UN, the US and the EU (including the UK), and any other applicable regime — and the questionnaire is how it obtains and documents assurance that each company on its register is clear.

The five regimes named each operate their own sanctions programmes, administered by their own authorities — for example, the US through the Office of Foreign Assets Control (OFAC) and the UK through the Office of Financial Sanctions Implementation (OFSI), alongside UN Security Council measures, EU regulations, and UAE domestic implementation. Because these regimes can differ in scope and in the persons they designate, screening against all of them together is necessary; a person clear under one may be designated under another. The questionnaire's reference to "and any other such laws where applicable" ensures the net is not artificially limited to those five where a further regime applies to the business.

The wider context is the UAE's sustained commitment to international financial-crime standards. The country has invested heavily in aligning with the expectations of bodies such as the Financial Action Task Force, and exited the FATF grey list in February 2024. Sanctions compliance is a core pillar of that architecture, sitting alongside anti-money-laundering and counter-terrorist-financing controls. A registry that collects and monitors sanctions declarations from every entity is demonstrating precisely the kind of control that international assessment expects — and it is protecting the legitimate businesses on its register from being tainted by association with those who are not clear.

What is the 15-day notification duty and the strike-off risk?

The declaration is not a one-off. The questionnaire imposes an ongoing duty to notify RAK ICC in writing within 15 days of any change in the information declared, and it records that RAK ICC reserves the right to strike off entities that do not comply with its sanctions policy. Signing the form is the beginning of the obligation, not the end of it.

The 15-day rule matters because sanctions positions can change suddenly and through no fault of the company. A new shareholder, a change of director, a new supplier or market, or — critically — a fresh designation by one of the five authorities can move a company from clear to exposed overnight. The obligation to notify within 15 days of a change means the company must actively monitor both its own circumstances and the evolving sanctions landscape, and report promptly when something shifts. A declaration that was accurate when signed but is left un-updated as circumstances change is not compliance; it is a stale form masking a live risk.

The strike-off power is what gives the policy teeth. Unlike some compliance failures that attract a warning or a penalty, non-compliance with the sanctions policy can result in the entity being removed from the RAK ICC register — with all the consequences that follow: loss of good standing, inability to obtain certificates, banking disruption, and the collapse of whatever the structure was built to do. This is a proportionate response to the seriousness of sanctions risk, and it means the questionnaire should never be treated as a formality. Keeping it current is a continuing obligation with a hard consequence for neglect, and it is one our corporate services team helps clients stay on top of.

How does sanctions screening connect to AML compliance?

They are two arms of the same financial-crime framework, and for a corporate service provider they should operate as one integrated function. Anti-money-laundering controls and sanctions screening share the same underlying data — the identity, ownership, control and connections of the people behind a company — and the same objective of keeping illicit activity out of the financial system. The sanctions questionnaire and the AML file draw on the same beneficial-ownership analysis and reinforce each other.

The overlap is practical, not just conceptual. The customer due diligence that the UAE AML framework requires — under Federal Law No. 20 of 2018 and Cabinet Decision No. 10 of 2019 — already establishes who owns and controls a company, who benefits from it, and who its key controllers are. That is precisely the information the sanctions questionnaire needs in order to screen Related Parties, apply the eight-part control test, and identify family and business-partner connections. A firm that runs strong AML due diligence has, in effect, already done much of the groundwork for sanctions screening; running the two separately duplicates effort and risks inconsistency between them.

There is also a shared escalation and reporting logic. Just as an agent may have obligations to report suspicious activity through the UAE Central Bank's goAML platform as a Designated Non-Financial Business or Profession, it must act on a sanctions match — which is generally a hard stop requiring the relationship or transaction to be halted, not merely monitored. Treating sanctions and AML as a single, coordinated compliance discipline — shared data, shared screening, shared escalation — is both more robust and more efficient than running them in separate silos. Building that integrated function is central to what we do within our compliance advisory.

How do you complete the sanctions questionnaire correctly?

You complete it by mapping every Related Party, screening each against live sanctions lists, working carefully through ownership and the eight-part control test, quantifying any exposure by percentage, answering each question honestly, and committing to keep the declaration current. It is a short form, but an accurate answer depends on real screening work behind it.

1. Map all Related Parties — list every shareholder, beneficial owner, key controller, trustee, founder, grantor, settlor and beneficiary, up to the natural persons.
2. Screen against live official lists — check each Related Party and the company against current UAE, UN, US, EU and UK sanctions sources, not just the countries printed on the form.
3. Apply the ownership and control tests — assess share ownership and then work through the eight control routes (a–h), remembering control can exist without shares.
4. Check territory and business activity — identify any presence in, or Business Activity (including via intermediaries or transhipment) involving, a Sanctioned Territory or Target.
5. Quantify and detail every “Yes” — provide the required percentage of shares or of Business Activity, and full details, for any exposure identified.
6. Sign, and set up ongoing monitoring — sign the confirmation, then monitor for changes and notify RAK ICC in writing within 15 days of any change.

The most important discipline is the second step. The countries on the form are a starting point, not the answer — genuine sanctions compliance requires screening against live official sources at the time you complete the questionnaire, because designations change constantly. A form completed by reading only the printed list, without live screening, can be honestly signed and still be wrong. If you are completing a RAK ICC sanctions questionnaire and want the screening done properly — the full Related-Party map, live checks, the control analysis, and ongoing monitoring — our AML and sanctions team can carry out the work and help you keep the declaration current.

One closing thought. A sanctions questionnaire can look like a box-ticking exercise, but sanctions is the one area of compliance where the consequences of getting it wrong are most severe and least forgiving — and where the honest answer depends entirely on the screening work behind it. Completed properly, with live screening and a full Related-Party map, it protects the company, the registry and the wider financial system. Completed carelessly, it is a signed statement that may simply be untrue. The difference is the diligence, not the form.