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Practice/Regulatory/Export Control
Area III

Export Control.

We advise companies subject to UAE, US, EU and UK export controls and sanctions. Licensing, restricted-party screening, ownership and control analysis, and the compliance programme behind it.

Instructing the firm
Every instruction is received by a partner.

The team is assembled around the matter, and it stays on the file.

info@amarapartners.ae
+971 2 550 0085
About this area

Most export-control rules are readable in an afternoon. The work is in the decision the rule forces you to make, and in the record that shows you made it.

Sanctions exposure usually turns up inside a transaction nobody flagged: a distributor appointment, a re-export, a payment routed through a UAE subsidiary, a counterparty whose ownership chain runs through a sanctioned jurisdiction. We look for it before the deal closes, then paper the decision so it holds up when a regulator or an auditor reads it back three years later.

We advise on classification and licensing, re-export risk, restricted-party screening, and ownership-and-control analysis where US primary sanctions concepts surface in structures that are otherwise UAE-domestic.

“Compliance is the record of the decision, made at the time.”

— Pillar II · Regulatory & Compliance

Programme design and testing sits alongside the transaction work: policies, training, internal audits, and voluntary disclosure mechanics when a breach turns up. Both are built to what the client's board and external auditors will need to see.

The work, in detail

Four matter types we handle in export control.

Classification and licensing.

Product and technology classification under the applicable regimes, and licence applications where one is needed. We draft the end-use and end-user undertakings to satisfy the licensing authority and to still make sense when the client's own compliance audit reopens them a year later.

Sanctions screening and structuring.

Ownership-and-control analysis where the OFAC fifty-percent rule or its equivalents is in play. Sectoral sanctions analysis for energy, financial services and defence-adjacent transactions. Advice on payment routes, counterparty selection and contractual carve-outs, while the structure can still be changed.

Third-party due diligence.

Diligence on distributors, agents and channel partners, with a written record of how each red flag was resolved. The contract then carries the terms that let the client act on what the diligence found: audit rights, compliance representations, termination triggers.

Programme design and disclosure.

Programme design and testing: policies, training, audit cadence. Voluntary disclosure has its own mechanics, and the way the first one is made tends to set the tone of everything after it.

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Discuss an export control matter with us.

We're available to assess your position and advise on the most effective approach. Initial conversations are always without obligation.