UAE Issues New AML Law to Strengthen Anti-Money Laundering and Counter-Terrorist Financing Framework

Publication has been written with assistance from Katie Edwards.

Introduction

The UAE has issued Federal Decree Law No. 10 of 2025 (the New Law) in a move to further enhance its anti-money laundering (AML) and counter terrorist financing (CTF) legal and regulatory framework. The New Law repeals and replaces Federal Decree Law No. 20 of 2018, reinforcing the UAE’s commitment to the Financial Action Task Force's (FATF's) 40 Recommendations – the global standard for combatting money laundering (ML), terrorist financing (TF), and the financing of weapons of mass destruction (proliferation financing / PF).

The New Law follows the European Union's recent decision to remove the UAE from its list of high-risk jurisdictions with strategic AML/CTF deficiencies. By further aligning its legislative framework with the FATF's standards and international best practices, the UAE continues to seek to position itself as a secure and attractive place to conduct business.

Key Changes

• New Offences: The New Law introduces new offences, including in relation to the criminalisation of arms and proliferation financing, making it illegal to finance without authorisation, directly or indirectly, arms or weapons of mass destruction (including related dual-use goods and technology). The New Law also clarifies that a TF offence may be committed by anyone who finances terrorism by the use of digital systems, virtual assets, or encryption technologies if they know, which may be implied, that the funds will be used for such purpose.
• Lower Evidentiary Threshold: Previously, prosecutors were required to prove actual knowledge that funds are criminal proceeds, or will be used for TF, for a ML or TF offence to be committed. Under the New Law, "sufficient evidence or circumstantial evidence" is enough, and knowledge can be inferred from the "factual and objective circumstances". This means that ML, TF and PF offences can be committed if a person knew, or should have known, that an offence would be committed. This change aligns with other jurisdictions, such as the UK, making it easier to prosecute ML, TF and PF offences.
• New Oversight Bodies: A new Supreme Committee has been created to oversee the National Committee for Combatting Money Laundering and the Financing of Terrorism and Proliferation, which is mandated to prepare and implement national strategies to improve regulatory compliance, assess crime risks, facilitate information exchange with domestic and international authorities, propose relevant regulation and represent the UAE internationally. The Supreme Committee is tasked with supervising the UAE's strategy for combatting ML, TF and PF, including coordinating strategy, assessing effectiveness and proposing legislative changes.
• Greater Investigative and Enforcement Powers: The Financial Intelligence Unit can now, among other things:
  • freeze funds for up to 30 days as opposed to 7 days (and this period can be further extended by order of the Public Prosecutor); and
  • suspend transactions for up to 10 working days without prior notice.

Federal and local law enforcement agencies are granted broad authority to access any information necessary to identify and track criminal property, likely resulting in an increase in UAE investigations and enforcement actions.

• International Cooperation and Asset Recovery: The New Law makes it easier to recover, seize, and confiscate criminal proceeds by allowing the enforcement of foreign judgments and court orders related to the confiscation of criminal proceeds, even where there is no UAE national investigation or ratified Convention with the foreign jurisdiction.
• Sanctions and Penalties: Sanctions and penalties have also increased and penalties for new offences have been imposed. For example:
  • For certain offences, fines will now match the value, or even twice the value, of the criminal property, where such value is higher than the maximum stated fine for the applicable offence.
  • There is now no upper limit on fines for certain offences, including "tipping off" (i.e., alerting a person to a ML investigation).
  • Legal entities can be fined up to AED 100 million (previously capped at AED 50 million) if their representatives, managers or agents commit a ML, TF or PF offence on their behalf or in their name. Similarly, legal entities can be subject to a fine of up to AED 10 million if their representatives, managers or agents commit any other crime punishable under the New Law.
  • Managers can be personally liable if they knew about the crime or the crime occurred due to a breach of their duties.
  • New penalties also apply to a range of new offences, including:
    • promoting, selling or using privacy-enhancing virtual asset products and services that fully conceal identity or impede tracing;
    • possessing, concealing or conducting any transaction involving funds where there is sufficient evidence or circumstantial evidence of the illegality of its source or concealment of its true beneficiary;
    • failing to comply with UAE sanctions authority instructions;
    • intentionally providing false or misleading beneficial ownership information; and
    • knowingly allowing a third party to use an individual's bank or Virtual Asset Service Provider account for unlawful conduct.

What does this mean?

The New Law significantly enhances the UAE's framework for combatting ML, TF and PF. It strengthens investigative and enforcement mechanisms and places greater responsibility on corporates and senior managers to prevent misconduct.

Under the New Law, companies can now be held liable not only for ML/TF offences committed by their employees and representatives - as was previously the case - but also for a much broader range of offences. Managers may also face personal liability not only for offences committed with their knowledge, but also for crimes arising from breaches of their obligations.

These developments may signal a shift toward more aggressive enforcement in the UAE, including potential prosecutions of corporate entities and their directors. This reflects similar trends in other jurisdictions, such as the UK, where corporates and senior managers may be held accountable for acts committed by representatives and employees. 

To mitigate risk, all businesses in the UAE - whether subject to full AML/CTF compliance obligations or not - should ensure they have appropriate policies and procedures in place. This includes preparing for increased scrutiny of corporate conduct, internal controls, and senior management oversight.

The introduction of the New Law is particularly timely in light of the FATF's upcoming mutual evaluation of the UAE, which is due to take place in 2026. By expanding the scope of its previous framework, the UAE continues to drive a largescale reform as it seeks to align itself with international best practice and solidify its reputation as one of the world's leading financial and economic centres.

If you have any questions about the implications of this update, or how you can protect your business, please reach out to the authors. 

Looking ahead, we will be hosting a breakout session at DLA Piper’s Middle East In-House Counsel Day on Tuesday, 28 October 2025: “From sanctions to supply chains: Practical insights on third party due diligence.” During this session, our team will explore how to effectively conduct third party due diligence, with a focus on evolving risk areas such as sanctions, criminal history, conflicts of interest, and supply chain vulnerabilities.

Should members of your legal team be interested in attending, please feel free to share the registration link with them that can be accessed below.

We look forward to welcoming you there!