Compliance

Service coverage

Front Row is licensed in Dubai, United Arab Emirates, and provides services to clients worldwide. Every engagement is subject to UAE law and to the sanctions, embargo and export-control regimes that apply to a UAE-licensed company.

Where we work

We accept clients from any jurisdiction, and we deliver remotely in English, Arabic and Italian. The United Arab Emirates does not publish a list of prohibited countries; its framework is targeted screening against designated persons and entities. Eligibility therefore depends on who the client is, not simply on where they are. Cross-border engagements are contracted under UAE law unless otherwise agreed in writing.

What we screen against

Before we open an engagement, and periodically during it, we screen the client, its beneficial owners and its counterparties against the following lists.

Applied to every engagement

United Nations Security Council
Consolidated List of designated individuals and entities.
Official source
UAE Executive Office for Control & Non-Proliferation
UAE Local Terrorist List, implemented under Cabinet Decision No. 74 of 2020.
Official source

Applied where the engagement, payment route or counterparty has a nexus to that jurisdiction

US Office of Foreign Assets Control (OFAC)
Specially Designated Nationals list, where an engagement touches US jurisdiction.
Official source
European Union
EU consolidated financial sanctions, where an engagement touches EU jurisdiction.
Official source
UK Office of Financial Sanctions Implementation (OFSI)
UK consolidated list of financial sanctions targets, where an engagement touches UK jurisdiction.
Official source

When we decline

We decline, suspend or terminate an engagement, without liability, where a party is designated on an applicable list; where the engagement would breach sanctions, export controls, anti-money-laundering obligations or UAE law; where ownership or the source of funds cannot be established; or where a payment cannot be settled through a compliant banking channel.

Client obligations

At onboarding, clients confirm that neither they, their beneficial owners nor their counterparties are designated on any applicable sanctions list, and that funds used to pay for our services are of lawful origin. Clients undertake to notify Front Row promptly of any change. Front Row applies the regime in force at the time of the engagement. This page is a description of our internal compliance practice; it is not legal advice.

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