1. Context
The UAE has enacted Federal Decree-Law No. 10 of 2025 on Combating Money Laundering, Terrorism Financing, and Proliferation Financing (“New AML Law”), effective from mid-October 2025. It repeals and replaces Federal Decree-Law No. 20 of 2018, strengthening the national framework and reinforcing post–grey list compliance. The implementing Cabinet Decision No. 134 of 2025 (the “Executive Regulations”) entered into force in December 2025.

The new regime enhances enforcement, addresses emerging risks (including virtual assets, cross-border tax evasion, and proliferation financing), and introduces clearer governance and accountability duties for senior management. It also reinforces the independence of the FIU and the newly established Supreme Committee under the Presidential Court.

2. What does this mean in practice?
Review of policies, procedures, training and other internal documentation should be within immediate scope to assess the extent to which any enhancement is necessary to ensure compliance with the various elements of the New AML Law. The table below highlights the principal updates introduced under the New AML Law.

3. Key legal and regulatory changes
Expanded scope and coverage

• Introduces Financing of the Proliferation of Weapons of Mass Destruction (PF) as a third pillar alongside money laundering (ML) and terrorism financing (TF), covering dual-use goods, related technologies, and supply-chain/logistics exposure.
• Explicitly includes virtual assets, virtual asset service providers (VASPs), and digital systems or encryption technologies under AML/CFT coverage.
• Extends AML obligations to sectors such as virtual-asset service providers (VASPs), real estate, professional services, trade, logistics, manufacturing, and non-profits.

Broader and clearer definitions

• Predicate crimes now include direct and indirect tax evasion and may occur inside or outside the UAE if punishable in both jurisdictions.
• Client definition is more specific.
• Proceeds broadened to include any profit, recurring benefit, or derivative advantage from criminal property.

Lower evidentiary threshold – “Should Have Known”

• Prosecutors no longer need to prove actual knowledge that funds were illicit.
• Liability arises when a person knew or should reasonably have known, based on factual circumstances.

Enhanced FIU and law-enforcement powers

• The FIU may suspend or freeze transactions for up to 10 working days without notice; and freeze funds for up to 30 days, extendable by the Public Prosecutor.

Risk-Based supervision and continuous obligations

• Continuous monitoring of customer relationships and transactions is now more critical given the personal responsibility of managers.
• Entities should retain AML and due-diligence records indefinitely until the Executive Regulations clarify time periods (expected early 2026).

Accountability and governance: Board, senior management and managers

• Boards and senior management must be actively involved in AML oversight (e.g., minutes, escalation logs, and training).
• Managers face personal liability if offences occur under their supervision or due to a breach of duties (see below).

Penalties for the main offences (other offences are highlighted in the New Law)

• Administrative penalties: AED 10,000 to 5 million per violation; supervisors may suspend licenses, restrict activity, or remove senior management.
• Corporate fines: up to AED 100 million for ML/TF/PF offences.
• Managers can now be subject to personal criminal liability and risk exposure to a fine or imprisonment if they have actual knowledge of ML/TF/PF offence or if it occurred as a result of a breach of their employment duties.
• Individual penalties: up to AED 10 million and imprisonment of up to 10 years.

“Tipping Off”

• “Tipping-off” now extends to both intentional and grossly negligent acts, covering a wider range of prohibited disclosures and failures – including the mismanagement of frozen or seized funds – and introduces aggravated penalties where such conduct results in the loss or destruction of criminal proceeds.

No limitation period for ML/TF/PF offences

• Criminal proceedings shall not lapse by limitation for offences of ML, TF, or PF, nor shall the penalties or related civil claims lapse.

Protection and confidentiality provisions

• Safe harbour: no criminal, civil, or administrative liability for providing any required information or breaching any legal, contractual, or administrative secrecy constraints, unless it is proven that the reporting was made in bad faith to harm others.

International cooperation

• UAE can enforce foreign orders for “provisional measures” or confiscate criminal property (or sums of an equivalent value) without the need to carry out a local, UAE-based money laundering investigation.

New oversight architecture

• Establishes a Supreme Committee (under the Presidential Court) overseeing the National Committee responsible for national AML/CTF strategy.
• Confirms the EOCN as the national authority for financial-sanctions implementation.
• Formalises the FIU as an independent statutory body within the Central Bank.