• institutions and designated non-financial businesses and professions (DNFBPs), introduced new beneficial ownership requirements, and published new guidance including the Guidance on Implementation of an Effective Sanctions Compliance Programme in 2025 as released by the Qatar Financial Centre Regulatory Authority.

• Saudi Arabia: The 2018 FATF MER confirmed that Riyadh had established a comprehensive legal framework to implement TFS, noted its role in co-sponsoring designations at the UN 1267 and maintaining a domestic mechanism for UNSCR 1373 listings. The evaluation recognised the country’s ongoing building capacity to freeze assets and enforce restrictions automatically upon UN designation.

• UAE: Established a dedicated committee and workflow outlining the process for receiving updates from the UNSC regarding UN sanctions lists to ensure they promptly circulated to all relevant authorities responsible for enforcement, enabling necessary measures to be taken within 24 hours.

• Iraq: Through its 2015 AML/CFT law, reinforced by amendments in 2022, Iraq created a dedicated Committee for Freezing Terrorist Funds and extended its framework to cover proliferation financing, thereby meeting UNSCR obligations.

• Oman: Introduced mechanisms to implement UN-mandated Targeted Financial Sanctions (TFS) by introducing new Committee decisions including but not limited to National Counter-Terrorism Committee Decision No. 01/2022, integrated sanctions compliance into supervisory oversight, and undertaken risk assessments of the non-profit sector.

• Qatar: Enhanced supervision of both financial institutions and designated non-financial businesses and professions (DNFBPs), introduced new beneficial ownership requirements, and published new guidance including the Guidance on Implementation of an Effective Sanctions Compliance Programme in 2025 as released by the Qatar Financial Centre Regulatory Authority.

• Saudi Arabia: The 2018 FATF MER confirmed that Riyadh had established a comprehensive legal framework to implement TFS, noted its role in co-sponsoring designations at the UN 1267 and maintaining a domestic mechanism for UNSCR 1373 listings. The evaluation recognised the country’s ongoing building capacity to freeze assets and enforce restrictions automatically upon UN designation.

• UAE: Established a dedicated committee and workflow outlining the process for receiving updates from the UNSC regarding UN sanctions lists to ensure they promptly circulated to all relevant authorities responsible for enforcement, enabling necessary measures to be taken within 24 hours.

For businesses, compliance with the renewed UN sanctions regime is less about designing entirely new processes but rather about sustaining and updating the existing ones, e.g. through revising policies, due diligence and monitoring procedures. Nevertheless, even well-governed businesses may come under scrutiny if counterparties, trade flows, or transactions intersect with restricted sectors or designated entities or individuals. Both domestic regulators and international enforcement authorities are expected to examine closely whether companies, even inadvertently, facilitate sanctions evasion.

Regional Business Implications: What to expect?

The measures outlined above overlap with U.S. and EU restrictions already in force, but they raise the compliance bar by obliging companies to show proactive alignment and to anticipate closer oversight by regulators and international partners. Key sectors of exposure mostly include:

1. Banking and Finance

2. Trade, Logistics and Shipping

3. Energy and Commodities

4. Corporate Governance

In effect, what this implies is that companies would need to review any stakeholders with actual or potential Iran exposure and consider how the return of sectoral restrictions spanning asset freezes, oil gas, shipping, technology, and financial services could bear on current relationships or related transactions. Beyond compliance, the snapback increases the risk of instability in critical maritime corridors. For MENA states, whose economies are tightly bound to secure energy exports, such disruption risks are not theoretical. Even limited sabotage on tankers can send insurance premiums.