UAE New AML Law: Federal Decree-Law No. 10 of 2025

Regulation Name: Federal Decree-Law No. 10 of 2025
Date Of Release: 14 Oct 2025
Region: India
Agency: Central Bank of UAE

UAE Enacts Federal Decree-Law No. (10) of 2025: A Comprehensive Overhaul of AML, CFT, and CPF Regulations

In a landmark step toward strengthening its financial crime framework, the United Arab Emirates has enacted Federal Decree-Law No. (10) of 2025, modernizing and consolidating the national regime for Anti-Money Laundering, Combating the Financing of Terrorism, and Proliferation Financing. The new law replaces the 2018 decree and introduces significantly enhanced definitions, powers, supervisory mechanisms, penalties, and international cooperation tools.

This comprehensive legislation reflects the UAE’s commitment to global standards, its progress following FATF evaluations, and its long-term strategy to remain a trusted global financial hub.

Expanded and Modernized Legal Definitions

The decree introduces one of the most exhaustive definitions frameworks in the region. Key expansions include:

Broader definitions of funds and proceeds

Funds now explicitly include digital, electronic, and cryptographic assets, as well as economic resources such as natural resources, securities, and any yield derived from criminal activity.

Clear inclusion of Virtual Assets and VASPs

The law brings Virtual Asset Service Providers squarely under AML/CFT/CPF supervision, defining their activities and obligations at par with banks and DNFBPs.

Stronger characterization of terrorism and proliferation

The scope of terrorist acts, terrorist organizations, and proliferation financing includes indirect participation, support, or facilitation, and covers dual-use goods, technology, and digital methods of financing.

Beneficial Ownership clarity

The law mandates clear identification of Beneficial Owners across all entity types, including trusts, nominee structures, and legal arrangements. Cabinet-level regulations will further define BO identification procedures.

Money Laundering, Terrorist Financing, and Proliferation Financing Crimes Reframed

The decree retains the core structure of AML/CFT offences but expands it to cover modern risks.

Money Laundering (Article 2)

A person commits ML if they knowingly—or where sufficient indicators exist to believe—that funds are proceeds of crime and:

• – Convert, transfer, or transact to conceal their illicit origin
• – Disguise the true nature, movement, or ownership
• – Acquire, possess, or use proceeds
• – Assist the predicate offender in evading punishment

Important: ML is treated as an independent crime, meaning conviction of the predicate offence is not required.

Financing of Terrorism (Article 3)

Financing terrorism is criminalized regardless of the legitimacy of the source of funds, and regardless of whether the financed act is completed. This includes financing travel for terrorist purposes.

Proliferation Financing (Article 3)

The law introduces comprehensive offences relating to financing weapons of mass destruction, dual-use technologies, or activities restricted under UN Security Council frameworks.

Stronger Supervisory and Enforcement Powers

The decree centralizes and strengthens investigative authority through:

Financial Intelligence Unit (FIU)

Located within the Central Bank but operating independently, the FIU (Article 11):

• – Receives all STRs from FIs, DNFBPs, and VASPs
• – Suspends or freezes suspicious transactions for up to 30 days
• – Exchanges information domestically and internationally
• – Maintains secure databases with cybersecurity requirements

Public Prosecution and Courts

Authorities can order seizure, freezing, valuation, tracing, and travel bans without prior notice.
Investigative powers include surveillance, access to IT systems, undercover operations, and controlled deliveries (Articles 6–9).

Supreme Committee & National Committee

Two national bodies ensure high-level governance:

• – The Supreme Committee, linked to the Presidential Court, supervises national AML/CFT strategy.
• – The National Committee, chaired by the Central Bank Governor, coordinates policy, risk assessments, and international engagement.

Obligations for Financial Institutions, DNFBPs, VASPs, and NPOs

Suspicious Transaction Reporting (Article 18)

Entities must file STRs without delay, regardless of transaction value. Confidentiality claims cannot prevent reporting.

Risk-Based Approach (Article 19)

• – FIs, DNFBPs, and VASPs must:
• – Conduct enterprise-wide ML/TF/PF risk assessments
• – Implement CDD and ongoing monitoring
• – Establish internal controls covering branches/subsidiaries
• – Maintain records and execute Targeted Financial Sanctions
• – Avoid anonymous, fictitious, alias, or numbered accounts

Beneficial Ownership and Transparency

Companies, nominee directors/shareholders, trusts, and NPOs are subject to enhanced transparency obligations.

Licensing Requirement (Article 20)

No person may conduct financial, DNFBP, or VASP activity without licensing or registration with the competent authority.

Administrative Sanctions

Supervisory authorities may impose strict penalties, including:

• – Warnings
• – Fines from AED 10,000 to AED 5 million per violation
• – Restrictions on business activity
• – Suspension or removal of responsible personnel
• – Appointment of temporary supervisors
• – License suspension or revocation

Public disclosure of penalties (Article 17)

International Cooperation & Asset Recovery

The UAE significantly expands its cross-border enforcement capabilities:

International Cooperation (Article 21)

The UAE may provide and request cooperation without restrictions related to:

• – Tax offences
• – Financial secrecy
• – Financial institution confidentiality

Foreign freezing, seizure, or confiscation orders can be executed without national investigations, subject to safeguards.

Asset Recovery (Article 22)

Cabinet regulations will govern asset management, disposal, and sharing. Proceeds remain subject to bona fide third-party rights.

Penalties and Criminal Liability

The law introduces some of the region’s strongest sanctions.

Money Laundering (Article 26)

• – 1–10 years imprisonment
• – AED 100,000 to AED 5,000,000 fine (or value of criminal property)
• – Up to AED 10,000,000 for aggravated cases
• – ML through NPOs, organized crime, or recidivism carries higher penalties

Financing Terrorism

• – Life imprisonment or temporary imprisonment (10+ years)
• – Fines up to AED 10,000,000

Proliferation Financing

• – Temporary imprisonment
• – Fines up to AED 10,000,000

Legal Persons (Article 27)

Companies may face:

• – Fines up to AED 100,000,000
• – Dissolution for FT/CPF cases
• – Closure of premises
• – Liability for management if negligence enabled the crime

Other Offences

The decree also criminalizes:

• – Failure to report STRs
• – Tipping-off
• – Mismanagement of frozen/seized funds
• – Possession of illicit funds (Article 30)
• – Enabling illicit use of accounts
• – Violating TFS measures
• – Providing false BO information

Deportation of Foreign Offenders

Mandatory for ML and felony offences; optional for other misdemeanors.

No Statute of Limitations :ML, FT, and PF crimes have no expiry for prosecution or penalties (Article 37).

Transparency, Statistics, and Confidentiality: Authorities must maintain advanced AML/CFT/CPF datasets, enabling national-level analysis and FATF-aligned assessments (Article 23).
Information related to STRs and related investigations is strictly confidential (Article 24).

Transition and Implementation: The decree:

• – Repeals the 2018 AML law
• – Retains prior regulations until replaced
• – Takes effect two weeks after publication in the Official Gazette (Article 42)

Conclusion

Federal Decree-Law No. (10) of 2025 marks a major evolution of the UAE’s financial crime framework. By strengthening supervisory powers, enhancing penalties, expanding the scope to digital assets and proliferation financing, and embedding international cooperation mechanisms, the UAE positions itself at the forefront of global AML/CFT compliance.

For financial institutions, DNFBPs, virtual asset providers, and NPOs, the law signals a new era of rigorous enforcement, risk-based regulation, and heightened accountability. As the Executive Regulations are issued, all obligated entities must proactively upgrade their systems, governance structures, and risk controls to ensure full compliance.

Read about the law here.

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