United Arab Emirates: Crackdown on peaceful dissent through terrorism listing

On January 8, 2025, the United Arab Emirates (hereinafter “UAE”) unilaterally added 11 individuals and eight entities to its terrorism list for their alleged links to the Muslim Brotherhood. The listing targets exiled peaceful political dissidents, human rights defenders, their relatives, and affiliated companies based outside the UAE. This act of transnational repression was taken without due process and reflects a broader pattern of repression whereby the Emirati authorities employ counter-terrorism frameworks, including administrative measures, to target and silence legitimate expression and human rights advocacy, including beyond its borders.

1. Patterns of repression through terrorism listings

1.1 Background: increased repression since 2012

In March 2011, 133 activists, including some members of al-Islah, signed a petition calling for increased political participation and constitutional reforms in the UAE. From March to July of 2012, UAE state security forces launched a wave of arrests against all signatories. On January 7, 2013, 94 defendants, including human rights defenders, lawyers, judges, academics and students, were charged with founding, organising and administering an organisation aimed at overthrowing the government, on the basis of articles 117, 180(1) and 182 of the country’s Penal Code. They were tried in what is commonly known as the “UAE94” trial.

In 2013, the UN Working Group on Arbitrary Detention (hereinafter “UN WGAD”) issued Opinion No. 60/2013 regarding the 61 convicted individuals of the UAE94 case, declaring that their deprivation of liberty is arbitrary. Although most had completed their prison sentences, many were not released and were instead held under the UAE’s “munasaha” regime, a so-called “rehabilitation” framework that has been used to prolong detention beyond sentence expiry without adequate legal safeguards. UN experts have repeatedly warned may enable arbitrary and even indefinite detention without adequate safeguards, including in the UN WGAD Opinion No. 19/2023 and a communication from Special Procedures.

In 2023, Emirati authorities brought new terrorism-related charges against 84 individuals – known as the “UAE84” trial, many of whom had already been sentenced in the UAE94 trial. 43 individuals were sentenced to life imprisonment by the Abu Dhabi Court of Appeal and the rest were sentenced to 10 to 15 years in prison on July 10, 2024.

Among those impacted by the 2025 terrorism listing, two were previously tried in absentia in the UAE94 and UAE84 mass trials, while three others are family members or acquaintances of individuals tried in those proceedings. These links demonstrate an association between the UAE94 and UAE84 trials and the selection of individuals designated in 2025.

1.2 Previous terrorism listings in 2014 and 2021

The UAE has long weaponised arbitrary terrorism listings as tools of repression. On November 15, 2014, the UAE Cabinet approved a list of 83 designated terrorist organisations under the 2014 Counter-Terrorism Law. The list included well-known civil society and humanitarian organisations, as well as Western Muslim charities that operate legally in the United States and Norway.

On September 14, 2021, the UAE Cabinet issued Resolution No. 83 of 2021, designating 38 individuals and 15 entities as supporting terrorism. The majority of those designated are absent from other international terrorism and financial sanctions lists, with only 14 of the 38 individuals and two of the 15 entities appearing on such lists. The list notably included several prominent exiled Emirati dissidents – namely Ahmed Mohammed al-Shaiba al-Nuaimi, Hamad Mohammed al-Shamsi, Mohammed Saqr al-Zaabi, and Saeed Nasser al-Tenaiji – who were the subject of concerns raised by UN human rights experts in a Special Procedures' communication AL ARE/2022, which highlighted the absence of evidence linking them to terrorist activity and raised serious concerns regarding the arbitrary nature of their designation.

2. The January 2025 listing: impacted individuals and entities

On January 8, 2025, the UAE Cabinet issued Resolution No. 1 of 2025, adding 11 individuals and eight entities to its terrorism list for their alleged links to the Muslim Brotherhood. Those impacted include political dissidents, their relatives, and affiliated companies. None of the individuals or entities designated in this 2025 listing are included in any other internationally recognised terrorism lists.

2.1 Emirati dissidents tried in absentia

Two of the 11 individuals included in the UAE’s 2025 terrorism list were previously convicted or accused of a terrorist offence. Among those listed is Jasem Rashed al-Shamsi, who was prosecuted in absentia in the UAE94 and UAE84 mass trials for exercising his right to freedom of expression. He was subsequently convicted of supporting or belonging to an organisation allegedly seeking to overthrow the government. Another individual, Abderrahman Omar Salim Bajubair al-Hadhrami, was convicted in a separate case for supporting members of the UAE94.

2.2 Relatives and associates of political dissidents

Three further individuals included in the terrorism list are family members – including children and in-laws of political prisoners – as well as acquaintances living abroad who maintain personal or familial ties with members of the UAE94 or UAE84. None of these individuals has been charged with or accused of any crimes.

These are Yousef Hassam Ahmad al-Mulla, son-in-law of political detainee Fouad al-Hmadi, subject of the UN Working Group on Arbitrary Detention (UN WGAD)’s Opinion No. 19/2023; Khalid Obaid Yousif Buataba al-Zaabi, whose father was arrested in 2012, and whose uncle, Judge Ahmed al-Zaabi, is detained and has been sentenced in both the UAE 94 and UAE 84 cases; and Abdul Rahman Hasan Munif Abdullah al-Jabri, son of political detainee Hassan al-Jabri, who is subject to the UN WGAD’s Opinion No. 19/2023 and had his nationality revoked.

2.3 Emiratis in exile who were never sentenced or accused of any crime

The six remaining individuals included in the terrorism list are Emirati nationals living in exile who have neither been charged nor convicted of any criminal offence, and who have never previously been listed as terrorists by the UAE. Most of these individuals left the UAE in the aftermath of facing increasing restrictions, amid concerns of reprisal or persecution similar to those faced by other reform advocates. Most departed the UAE around 2012 – when mass arrests of peaceful dissidents began – and have since lived in self-imposed exile. Despite this, they were subsequently included in the 2025 terrorism listing without any charges or criminal convictions forming the basis of their designation.

These individuals are Saeed Khadem Ahmed Bintouq al-Marri, Ibrahim Ahmed Ibrahim Ali al-Hammadi, Elham Abdulla Ahmad al-Hashemi, Humaid Abdulla Abdulrahman Jumaa al-Nuaimi, Ali Hasan Ali Husain al-Hammadi and Mohamed Ali Hasan Ali al-Hammadi.

2.4 UK-registered companies owned by exiled dissidents and their relatives

The eight companies added to the terrorism list are owned by exiled dissidents sentenced as part of the UAE94 and UAE84 trials, or by their relatives. All of these entities are registered in the United Kingdom and operate in legitimate sectors such as education and student consultancy, with no known association with unlawful activity.

LTD Center Training and Education Cambridge, LTD INE6IMA, and LTD Tree Wembley are owned by Ahmed Mohammed Abdullah Mohammed al-Shaiba al-Nuaimi. He was previously listed as terrorist by the UAE in Cabinet Resolution No. 83 of 2021. Waslaforall is an Instagram-based initiative focused on teaching Arabic to children, owned by the daughter of Ahmed al-Shaiba al-Nuaimi.

LTD Graduates Future is a UK-based company previously owned by Mohammed Saqr Yousif Saqr al-Zaabi, who has not had any affiliation with the company since 2021. He was also previously listed as terrorist by the UAE in Cabinet Resolution No. 83 of 2021.

Estate Real and Investment for Yas, Capital Nafel, and Limited Properties UK Holdco are owned by Abdul Rahman Hasan Munif Abdullah Hasan al-Jabri, son of political detainee Hassan al-Jabri who is the subject of the UN WGAD’s Opinion No. 19/2023.

3. Legal framework

3.1 The Federal Law No. 7 of 2014 on Combating Terrorist Offences

The individuals and companies designated in the January 2025 terrorism listing were listed pursuant to Federal Law No. 7 of 2014 on Combating Terrorism Offenses (hereinafter “2014 Counter-Terrorism Law”). Specifically, the legal framework governing terrorism listing can be found in article 63.

Article 63(1) of the 2014 Counter-Terrorism Law states that the “Cabinet may, based on the proposal of the Minister of Presidential Affairs, issue a decision on the creation of a list(s) of terrorist organisations or persons that pose threat to the State.”

According to article 63(2):

the Cabinet Decision on the creation of the lists shall specify the rules of inclusion, write-off and re-inclusion as well as the legal effects resulting from all the aforementioned. Moreover, the aforesaid decision shall specify the authority(ies) in charge of such procedures in addition to the methods and rules of grievance against their decisions. Every person whose name is included in the terrorism lists may file a grievance against the inclusion decision. If the grievance is rejected or no reply thereto is issued within 60 days from the date of its filing, the grievant may challenge the inclusion decision before the competent court within 60 days from the date on which such person is informed of the rejection or expiry of the reply deadline.

Article 63(3) states that the “decision shall specify the methods and rules of revision of terrorism lists, provided that revision is carried out within regular periods not exceeding one year each.”

3.2 Cabinet Decision No. 74 of 2020: Terrorism lists regulation and implementation of UN Security Council Resolutions

The individuals and companies designated in the UAE’s January 2025 terrorism listing were added to the UAE’s domestic terrorist list pursuant to Cabinet Decision No. 74 of 2020 on the UAE List of Terrorists and the Implementation of UN Security Council Decisions. The UAE thus appears to frame these designations as part of its domestic implementation of UN Security Council counter-terrorism obligations, particularly the designation framework associated with UN Security Council Resolution 1373 (2001), under which the UAE’s Supreme Council for National Security may propose unilateral listings, without prior notice and irrespective of whether criminal proceedings exist, for approval by the Cabinet.

Article 3(1) of Cabinet Decision No. 74 of 2020 stipulates that:

The Council shall, unilaterally and without prior notice to the Listed Person, establish one Local List or more where it proposes the Listing of terrorist persons and organizations, or propose Listing upon the request of another country, whenever the Council is satisfied with the presence of reasonable grounds or sound basis for suspicion or when it believes that such person or organization meets the designation criteria for Listing, or if the State is internationally committed to list such persons and organizations. The Council shall take such decision as swiftly as possible.

4. Legal analysis and human rights concerns

4.1 Overly vague definition of terrorism and terrorist organisation

Terrorism listing in the UAE relies upon the country’s national definition of terrorism. The 2014 Counter-Terrorism Law contains a vague and overly broad definition of terrorism, referring to “terrorist purpose” and “terrorist result” instead of defining the term directly. UN human rights experts criticised this definition for “essentially remain[ing] undefined, as one definition refers or defers to another without clearly providing a concrete and constrained definition of the activities they encompass”. 

While the 2014 Counter-Terrorism Law does not provide a definition for a “terrorist act”, it defines a “terrorist organisation” as a group “that commits a terrorist act, directly participates in, threatens of, aims at, plans, seeks, promotes or aids the commission of such act regardless of the name, form, place of establishment, location, nationality or place of existence of its members.” The law also describes a “terrorist” as “whoever belongs to a terrorist organization, commits a terrorist offence, participates directly or indirectly in causing its commission, or threatens of, aims at, plans, seeks, promotes or aids the commission of such commission.”

UN human rights experts, including the Special Rapporteur on the promotion and protection of human rights and fundamental freedoms while countering terrorism, stated that “what constitutes a ‘terrorist’ or a ‘terrorist organisation’, or even the understanding of the concept of ‘membership’ […] remain open to subjective interpretation due to the lack of clarity of these interrelated terms.” The experts added that “this subjectivity, as well as the confusing and unclear nature of all of these key definitions, seem to repeatedly undermine the principle of legal certainty”, concluding that “it would be difficult for an individual or organisation to regulate their conduct or operations according to the law when the law itself does not properly limit or even enunciate the activities it is criminalising.”

According to the UN experts, “any subsequent list of ‘terrorist organisations’ created in light of article 63 (1) may potentially include organisations or groups who had simply expressed criticism of the ruling authorities or whose religious views or political positions are perceived as contrary to the interests or the ‘basic principles’ of the State, rather than groups that pose a concrete terrorist threat.” The experts highlighted that the combination of an imprecise definition of “terrorist organisation” and terrorist-related offences contained in the 2014 counter-terrorism law only increases the risk that article 63 (1) might be abused or misused.

4.2 Excessive powers granted to the executive branch

Article 63 of the 2014 Counter-Terrorism Law grants the executive branch broad authority over terrorist designations. Under article 63(1), the Cabinet may issue a list of terrorist organisations or persons threatening the security of the State at the request of the Minister of Presidential Affairs. Article 63(2) further provides that the rules governing inclusion, removal, re-inclusion, legal consequences, the competent authorities, and the grievance procedure are to be specified by a subsequent Cabinet decision. In other words, the primary law delegates the procedural safeguards governing designation to the executive itself, rather than prescribing them in legislation.

This is reinforced by article 3(1) of Cabinet Decision No. 74 of 2020 on the UAE List of Terrorists and the Implementation of UN Security Council Decisions, which provides that the Supreme Council for National Security may, “individually and without prior notice to the designated,” prepare a local terrorist list and submit it for Cabinet approval. The listing process is therefore a unilateral executive decision, taken without prior notice to the affected person and without any requirement of prior judicial oversight.

In 2020, UN human rights experts raised precisely this concern. They observed that article 63 appears to give the Minister of Presidential Affairs “significant discretion” to label any organisation a terrorist entity, since subsequent terrorist organisation lists created by the Cabinet or related judicial rulings seem to be based on the Minister’s initial proposal. They further warned that, in the apparent absence of any clear procedure or oversight, the Minister and the executive branch more broadly could approve proscription “without being required to legally demonstrate that there is objective reason to believe that such a designation is justified.”

Given the broad and imprecise definition of terrorism and other related offences included in the 2014 Counter-Terrorism Law, the experts warned that “the attribution of undefined and seemingly unconstrained powers to the executive could contribute to an arbitrary and unreasonable use of these powers.”

4.3 Lack of a defined procedure for terrorism listing designations

Article 63 of the 2014 Counter-Terrorism Law does not outline the procedure that should be followed by the authorities in making a determination about whether an organisation may be added to a terrorism list. Instead, as highlighted by UN human rights experts, it solely indicates that this information will be outlined in a subsequent Cabinet Decision, rather than setting out those safeguards in the primary law itself. The experts have warned that this legislative design is “deeply concerning” and insufficiently precise to satisfy the principle of legal certainty.

The subsequent framework is set out in Cabinet Decision No. 74 of 2020. Article 3(1) provides that the Supreme Council for National Security may prepare a local list “without prior notice” to the designated person or organisation, on the basis of “reasonable grounds” or a “sound basis for suspicion or belief,” and submit it for Cabinet approval. Article 5 then provides that decisions concerning local terrorist lists enter into force upon issuance and are to be published in the Official Gazette and in Arabic- and English-language media.

In these provisions, the Cabinet Decision does not establish any clear requirement of individualised notification to persons placed on the local list, nor does it require that they be informed directly and promptly of the factual basis for their designation before the consequences of listing take effect. Although, article 63(2) of the Counter-Terrorism Law states that a person whose name is inserted in the terrorism lists has the right to file a grievance, which presupposes that the person is aware of the designation, it does not signify that the person has been formally notified.

The problem is compounded by article 21(7) which obliges financial institutions and Designated non-financial Businesses and Professions (DNFPBs) to adopt policies prohibiting employees from informing the customer or any third party, directly or indirectly, that freezing or other measures will be applied. As a result, the framework ensures rapid implementation of restrictive measures while making it harder for the affected person to learn of those measures through their bank or other intermediary.

These gaps stand in stark violation of international standards, which, according to UN human rights experts, require that listed organisations or individuals be “promptly informed of the listing, its factual grounds, consequences, and applicable procedural rights.”

Even where Cabinet Decision No. 74 of 2020 does provide for notification, that safeguard is limited. Article 11(3) requires notification only of a person listed on the sanctions list who is residing in the State, and only after the completion of the funds freezing procedures. It also provides that the person should receive an explanatory summary or the necessary information on the grounds for designation and the applicable delisting procedures. This provision does not appear to apply to persons designated on the local terrorist list, and in any event would not cover many of the exiled individuals discussed in this analysis.

4.4 Absence of an effective remedy

According to Article 63(2) of the 2014 Counter-Terrorism Law:

A resolution by Council of Ministers shall determine the provisions in respect of inserting, removing or reinserting terrorist organizations in such list, as well as the legal consequences of the same. Such resolution shall determine competent authorities, as well as the rules of filing grievances in respect of the same. A person whose name is inserted in such list shall has the right to file a grievance in respect of the same. If the grievant has not received any comment within sixty days from filing such grievance, the grievant is entitled to challenge the decision of insertion within sixty days from the date of rejecting such grievance or delay of the comment thereof.

While this provision formally recognises that a listed person may file a grievance against their inclusion on a terrorism list, it does not itself set out the applicable procedure, the competent authority, the deadline under which such a grievance needs to be filed or the manner in which it is to be examined, instead leaving these matters to a subsequent Cabinet decision.

Additional rules are set out in article 6 of Cabinet Decision No. 74 of 2020 on the UAE List of Terrorists and the Implementation of UN Security Council Decisions. Article 6(1) requires the listed person or organisation to submit a written grievance to “the Office” in accordance with the mechanism determined by that Office. The Cabinet Decision does not itself explain further that mechanism and leaves the procedure vague. The Office then refers the grievance to the Supreme Council for National Security, which examines it and expresses its opinion. If the Supreme Council considers that delisting is warranted, the matter is transmitted through the Minister of Presidential Affairs to the Cabinet, which decides whether to approve or reject the grievance. Thus, the grievance remains entirely within the executive branch and ends in a decision by the same Cabinet that issued the listing in the first place.

While article 6(7) of Cabinet Decision No. 74 of 2020 allows the listed person to bring the matter before the competent court if the grievance is rejected, or if no decision is issued within sixty days, this judicial avenue is also limited. Article 6(8) expressly provides that the court’s decision is “incontestable”, meaning that no further appeal is available. It further states that, if the court rejects the grievance, no new grievance may be filed for six months unless the president of the court accepts that a serious reason justifies an earlier application.

5. Consequences for the listed individuals and entities

According to Human Rights Watch, the individuals who were listed have faced immediate and severe consequences under the 2014 Counter-Terrorism Law. Their assets are frozen and properties confiscated, effectively depriving them of financial resources and means of livelihood. Financial institutions were required to freeze their accounts and block all transactions associated with the designated individuals, cutting them off from the banking system and preventing them from engaging in normal economic activity. This financial isolation has also extended to their businesses, as any entities they own or are associated with could be closed or subjected to severe restrictions. Similarly, the listed entities faced substantial financial consequences, particularly due to the loss of clients, which disrupted their business operations.

Beyond the economic impact, designated individuals face severe criminal penalties. Under article 21 of the 2014 Counter-Terrorism law, anyone who provides, collects, or supplies funds – directly or indirectly – to a designated person or entity can face imprisonment and substantial fines. This provision is broadly interpreted to criminalise virtually any financial interaction with listed individuals, including routine family support or business transactions. Relatives and friends of listed individuals can face life imprisonment merely for communicating with them, as such contact can be construed as “supporting” a designated terrorist. This has created a chilling effect on families, forcing them to choose between severing contact with their loved ones or risking criminal prosecution.

6. Conclusions and recommendations

Resolution No. 1 of 2025 and past 2014 and 2021 terrorism listing have had chilling effects on the legitimate activities of Emirati activists, human rights defenders, dissidents and political opponents, and only further perpetuates a climate of silence and self-censorship in the UAE and abroad.

MENA Rights Group calls on the Emirati authorities to immediately rescind these abusive terrorism designations, provide reparations to those whose human rights and fundamental freedoms have been adversely impacted by the listings, and cease all acts of transnational repression. It further urges the UAE to repeal or comprehensively amend its counter-terrorism legislation to ensure full compliance with international standards. In particular, the UAE should amend key provisions of Federal Law No. 7 of 2014, specifically article 63, read in conjunction with article 1, with a view to bringing them into conformity with international human rights standards.