The UAE’s AML framework has changed: What businesses need to know

Author: Dhilna Dileep

The United Arab Emirates has introduced a new federal anti-money laundering regime that significantly strengthens its approach to combating financial crime. Federal Decree-Law No. 10 of 2025 regarding Anti-Money Laundering, Combating the Financing of Terrorism and Proliferation Financing (the AML Law) replaces the previous framework and introduces broader criminal offences, enhanced enforcement powers and substantially increased compliance expectations.

The AML Law repeals Federal Decree-Law No. 20 of 2018, while preserving existing executive regulations and implementing decisions to the extent that they do not conflict with the new provisions. It establishes a consolidated legislative framework governing money laundering, terrorism financing and proliferation financing across the UAE.

A broader scope of financial crime offences

The AML Law consolidates and expands the criminalisation of:

• Money laundering;
• Financing of terrorism; and
• Proliferation financing, including conduct linked to weapons of mass destruction.

Money laundering is expressly defined as an independent criminal offence. A conviction for the underlying predicate offence is not required to establish liability, and courts may infer knowledge or intent from objective factual circumstances. This materially lowers evidentiary thresholds in enforcement proceedings.

The law also recognises that money laundering and terrorism financing may be committed through digital platforms, virtual assets and cryptographic technologies, ensuring that the framework captures modern and evolving financial crime risks.

An expanded regulatory perimeter

The AML Law applies to a wide range of regulated persons, including:

• Financial institutions;
• Designated non-financial businesses and professions (DNFBPs);
• Virtual asset service providers (VASPs); and
• Non-profit organisations (NPOs).

All regulated persons must obtain the appropriate licence or registration and remain subject to ongoing supervision by competent authorities. Carrying out regulated activities without the required authorisation constitutes a criminal offence under the AML Law.

Stronger preventive and compliance obligations

The AML Law reinforces a risk-based approach to AML/CFT compliance. Regulated entities must:

• Identify, assess, document and regularly update money laundering and terrorism financing risks;
• Implement robust customer due diligence and ongoing monitoring measures;
• Identify and verify beneficial owners in accordance with Cabinet-issued procedures;
• Maintain transaction and customer records and ensure their prompt availability to competent authorities; and
• Implement targeted financial sanctions without delay.

Entities must submit Suspicious Transaction Reports (STRs) directly to the Financial Intelligence Unit without delay. The law expressly overrides confidentiality obligations for reporting purposes, subject to limited exceptions relating to legal professional privilege.

Enhanced investigative and enforcement powers

The AML Law grants extensive powers to the Financial Intelligence Unit, Public Prosecution and competent courts, including the authority to:

• Suspend or freeze suspicious transactions without prior notice;
• Order the seizure, freezing and confiscation of criminal property or funds of equivalent value;
• Conduct undercover operations and controlled deliveries; and
• Impose travel bans and restrict dealings in assets during investigations.

Notably, the law permits the enforcement of foreign confiscation and provisional measures without the need for a parallel domestic investigation, subject to applicable legal requirements. This significantly strengthens the UAE’s cross-border enforcement capabilities.

A stringent penalty regime

The AML Law introduces severe criminal and administrative penalties:

• Money laundering offences are punishable by imprisonment of up to ten years and fines of up to AED 5 million, with enhanced penalties in aggravated cases.
• Financing of terrorism may attract life imprisonment.
• Legal persons may face fines of up to AED 100 million, together with potential dissolution or closure in serious cases.
• Supervisory authorities may impose administrative sanctions, including licence suspension or revocation, activity restrictions and public naming of violations.

Criminal liability for money laundering, terrorism financing and proliferation financing offences does not lapse by prescription.

Implications for businesses operating in the UAE

Federal Decree-Law No. 10 of 2025 materially raises compliance expectations for businesses operating in or through the UAE. Boards, senior management and compliance functions must ensure that AML/CFT frameworks align fully with the new legislative requirements and any forthcoming executive regulations.

Failure to implement adequate systems, controls and governance measures may expose organisations and individuals to significant criminal, administrative and reputational risk. Early review and enhancement of AML/CFT programmes is therefore essential.

Conclusion

The new AML Law reflects the UAE’s continued commitment to international financial crime standards and significantly strengthens its enforcement framework. For businesses, the message is clear: proactive, well-governed and risk-based compliance is no longer optional.

Timely action will be critical to mitigating exposure and ensuring regulatory readiness under the new regime.

Note: This Legal Update / Newsletter is intended for general informational purposes only and should not be construed as legal advice. It is based on laws and legal interpretations in effect as of the date of publication. Laws and regulations may change over time, and their application can vary depending on individual circumstances. Readers are strongly encouraged to seek specific legal counsel before acting on any of the information provided herein.