IRU Circular 5/2026 — National designation-list monitoring and match notification
IRU Circular 5/2026 requires continuous monitoring of local and international designation lists, implementation of the relevant designation decisions, and notification of matches to the designated MFA committee and IRU AML office. It is not a static list that can be screened once and forgotten. Official sources and an evidence-led implementation checklist.
تعميم رقم (5) لسنة 2026 بشأن ادراج افراد وكيانات على القائمة الوطنيةOfficial Arabic title
- Issued
- 08.04.2026
- Published
- 09.04.2026
- Guide reviewed
- 11.10.2026
- Instrument
- IRU Circular 5/2026
Action at a glance
What this instrument asks you to do
IRU Circular 5/2026 requires continuous monitoring of local and international designation lists, implementation of the relevant designation decisions, and notification of matches to the designated MFA committee and IRU AML office. It is not a static list that can be screened once and forgotten.
Source-backed
Stated legal requirements
Requirements below are attributed to the instrument or cited guidance; each item includes its source location.
- 01
Continuously monitor local and international listings through the committee's system and implement designation decisions and the cited Articles 21–23.
Citation · Page 1, instruction 1
- 02
Notify matches between company database information and the local/international lists to both the specified committee and IRU AML-office channels.
Citation · Page 1, instruction 2
Dates and applicability
Timing, grace period and deadline
Timing
Signed 8 April; published 9 April. Continuous follow-up is specified; a separate fixed reporting window is not set out in this one-page circular.
Grace period
Only the specifically stated submission period or validity condition applies. No additional general grace period is asserted.
Expit suggested practices
Build a reviewable closure record
These suggested actions are implementation practices, not additional legal requirements.
- 01
Record which current official lists feed the screening process.
- Suggested owner
- MLRO / sanctions operations
- Evidence to retain
- List-source register, retrieval timestamps and ingestion tests
- Complete when
- Updates are monitored and failed ingestion is escalated, rather than relying on a dated copy.
- Expit support context
- Document extraction and reconciliation can support list updates; a qualified reviewer decides matches.
- 02
Test the two-recipient match-escalation workflow.
- Suggested owner
- MLRO
- Evidence to retain
- Reviewed match record and protected copies of official notifications
- Complete when
- A confirmed match has a documented decision and the required notifications, following applicable freezing rules.
- Expit support context
- Controlled workflows can track evidence; Expit does not file sanctions notifications for the firm.
Further clarification
Frequently asked questions
Is Circular 5/2026 itself the current sanctions list?
No. It requires monitoring and action against official lists; later designation and delisting decisions must also be checked.
Can Expit declare our national designation-list monitoring and match notification gap closed?
No. Expit can support document processing, evidence reconciliation and accountable workflows. Your responsible officers and advisers must assess legal applicability, complete any required official submission and approve closure.
Primary references
Official sources
- Official IRU Circular 5/2026 PDF (opens in a new tab)SOURCE 01
Operative circular visually reviewed. This guide does not reproduce the operative designation list or all freezing rules. MFA Decision 176/2025 and the current official lists control identification, treatment and any subsequent changes.
Read with care
Enforcement and limitations
Enforcement stated in source
The circular refers to IRU's powers under Insurance Law 125/2019 and applicable regulations/instructions. No fixed fine or individual enforcement outcome is inferred.
Limitations of this guide
This guide does not reproduce the operative designation list or all freezing rules. MFA Decision 176/2025 and the current official lists control identification, treatment and any subsequent changes.