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This new legislation has expanded the perimeter of regulated activity to bring virtual asset service providers (VASPs) within scope and thus establishing additional offences including those relating to PF by lowering the evidentiary threshold for prosecuting financial crime. It has also strengthened the powers available to regulators and enforcement authorities and has imposed tougher penalties.

As a result, immediate attention is required from financial institutions, designated non-financial businesses and professions (DNFBPs), compliance officers and senior management to ensure compliance.

At the core of the UAE’s AML/CTF/CPF regime is Federal Decree-Law No. 10 of 2025 itself. Its detailed application and procedural requirements are set out in Cabinet Resolution No. 134 of 2025, which serves as the implementing regulation to the federal law.

In addition, the relevant supervisory authorities issue sector-specific guidance to support regulated entities in meeting their obligations under the new framework.

Entities operating in the UAE’s financial free zones, such as the Abu Dhabi Global Market (ADGM) and the Dubai International Financial Centre (DIFC), must comply with their respective AML rulebooks while also adhering to applicable provisions of federal law.

History of UAE AML Regulations

Over the last ten years, the UAE has grown into an important international financial centre with strong cross-border connections. As this growth continued, the need to protect the financial system from misuse also increased. Financial crime risks have evolved over time and now include the use of digital assets, trade in dual-use goods and challenging ownership structures.

In response, the UAE government introduced its National AML, CFT and CPF Strategy for 2023 to 2027 and committed to applying the latest standards issued by the Financial Action Task Force (FATF).

Federal Decree-Law No. (10) of 2025 entered into force on 14 October 2025. With its entry into effect, it repealed Federal Decree-Law No. (20) of 2018, as well as Federal Decree-Law No. (26) of 2021, which had amended the 2018 AML legislation.

The operational and procedural framework supporting the 2025 AML Law is provided under Cabinet Resolution No. (134) of 2025, which became effective on 14 December 2025. This resolution revoked Cabinet Decision No. (10) of 2019 and Cabinet Resolution No. (24) of 2022, both of which related to the executive regulations under the former AML regime.

Federal Law No. (7) of 2014 on Combating Terrorism Crimes came into force on 1 September 2024, replacing Federal Decree-Law No. (1) of 2004 concerning the combating of terrorist crimes.

Matters relating to terrorist lists and the implementation of United Nations Security Council resolutions are governed by Cabinet Resolution No. (74) of 2020, which took effect on 29 October 2020. This resolution repealed Cabinet Resolution No. (20) of 2019, along with related resolutions addressing the regulation of terrorist lists, the suppression of terrorism and its financing and the prevention of weapons proliferation and associated financing.

The regime for administrative violations and penalties applicable to entities supervised by the Ministry of Justice and the Ministry of Economy is governed by Cabinet Resolution No. (71) of 2024. This resolution entered into force on 8 July 2024 and repealed Cabinet Resolution No. (16) of 2021, which had previously established a unified schedule of violations and administrative fines for AML and CTF breaches.

Cabinet Decision No. (109) of 2023 which addresses the beneficial owner procedures, became effective on 6 November 2023 and repealed Cabinet Resolution No. (58) of 2020, which had regulated beneficiary requirements.

Administrative sanctions applicable to violations of the beneficial owner framework are governed by Cabinet Resolution No. (132) of 2023, which entered into force on 30 December 2023. This resolution repealed Cabinet Resolution No. (53) of 2021, which had imposed administrative penalties for breaches of the earlier beneficiary regime.

Scope and Application: Entities Subject to AML Obligations in the UAE

The 2025 AML Law applies across a wide range of sectors. Its scope is designed to capture activities and entities that were previously subject to lighter regulation or uncertainty by ensuring detailed coverage of areas exposed to financial crime risk.

Categories of Persons and Entities Covered

The following categories fall within the scope of the UAE AML framework:

Financial Institutions

This includes entities such as banks, insurance and reinsurance companies, securities and commodities intermediaries, exchange houses and providers of payment and remittance services.

Designated Non-Financial Businesses and Professions (DNFBPs)

DNFBPs include real estate brokers and agents, auditors and accountants, lawyers, notaries and advocates, corporate and trust service providers, as well as dealers in precious metals and precious stones.

Virtual Asset Service Providers (VASPs)

The 2025 AML Law expressly brings virtual asset businesses within scope, including crypto exchanges, wallet service providers and platforms facilitating virtual asset transactions.

Other Natural or Legal Persons

Any individual or entity involved in or facilitating financial transactions within the UAE is subject to the AML regime, whether operating onshore or from a financial free zone such as the Dubai International Financial Centre (DIFC) or the Abu Dhabi Global Market (ADGM).

The law ensures that sectors traditionally vulnerable to misuse, including real estate, high-value goods, corporate services and virtual asset activities, are fully subject to regulatory monitoring.

AML and CTF Activities Relevant to Financial Institutions

Financial institutions are required to comply with AML and CTF obligations when carrying out activities that include, among others:

• Receiving deposits or other repayable funds from the public
• Providing credit facilities, including consumer loans, mortgages and financing of commercial transactions
• Conducting financial leasing activities by excluding leasing of consumer goods
• Offering money or value transfer services
• Issuing or managing payment instruments such as cards, cheques, drafts, payment orders and electronic money
• Providing guarantees and other financial commitments
• Trading in money market instruments, foreign exchange, derivatives, interest rate or index instruments, negotiable instruments and commodity futures
• Participating in securities issuance and delivering related financial services
• Managing investment funds and portfolios of any type
• Holding or administering cash or liquid securities on behalf of third parties
• Performing investment, management or administrative services involving client funds
• Underwriting or subscribing to life insurance and investment-linked insurance product
• Conducting currency exchange activities

AML and CTF Activities Relevant to DNFBPs

Designated Non-Financial Businesses and Professions are subject to AML requirements when engaged in specific activities, including:

• Real estate brokers and agents facilitating the purchase or sale of property on behalf of clients
• Dealers trading in precious metals or precious stones
• Lawyers, notaries, independent legal professionals and accountants when involved in financial transactions such as:

1. Buying or selling real estate
2. Managing client funds or assets 
3. Managing bank, savings, or securities accounts
4. Organising capital contributions for the formation or operation of companies
5. Establishing, managing, or transferring legal persons or legal arrangements

Company and trust service providers are covered when performing activities such as:

• Assisting with the incorporation or formation of legal entities
• Acting as, or arranging for others to act as, company directors, secretaries, partners, or similar positions
• Providing registered offices, business addresses, or administrative addresses
• Acting as trustee of an express trust or performing similar functions for other legal arrangements
• Acting as, or arranging for others to act as, nominee shareholders

In addition, operators of commercial gaming activities are included within the DNFBP category pursuant to Cabinet Resolution No. (134) of 2025 which is in effect from 14 December 2025.

AML and CTF Activities Relevant to Virtual Asset Service Providers

Virtual Asset Service Providers are subject to AML compliance requirements when conducting activities that include:

• Exchanging virtual assets for fiat currencies
• Exchanging one virtual asset for another
• Transferring virtual assets between parties
• Safeguarding or administering virtual assets, or tools that provide control over such assets
• Providing financial services related to the issuance, offering, sale, or participation in virtual assets

AML and CFT Supervisory Authorities in the UAE

The enforcement of federal AML and CFT legislation in the UAE is supported by designated authorities that are responsible for supervision and the issuance of guidance to regulated entities, in line with the powers granted to them under the applicable AML laws and regulations.

Financial Intelligence Unit (FIU)

The Financial Intelligence Unit (FIU) acts as the UAE’s central authority for the receipt and analysis of suspicious transaction and activity reports. From an AML perspective, the FIU serves as the primary reporting body for all regulated entities, regardless of the sector in which they operate or whether their activities are conducted onshore or within a free zone.

Executive Office for Control and Non-Proliferation (EOCN)

The Executive Office for Control and Non-Proliferation (EOCN) is responsible for the implementation and enforcement of the UAE’s targeted financial sanctions (TFS) framework. Its functions include receiving and reviewing sanctions-related reports, providing direction to regulated entities on sanctions compliance, and assessing reports relating to sanctions matches. All sanctions-related reporting to the EOCN is submitted exclusively through the goAML portal.

Conclusion

The 2025 AML Law changes how financial crime is handled in the UAE. It expands the types of entities covered, increases penalties, lowers evidentiary thresholds and gives regulators stronger enforcement powers.

Legal advisers, compliance teams, and senior management are now required to take a far more active role, with clear responsibility at board level, enhanced use of compliance technology, ongoing risk evaluation, and an emphasis on ethical conduct. The UAE has made it clear that misuse of its financial system for money laundering, terrorism financing, or the financing of weapons proliferation will not be accepted. For organisations prepared to strengthen their compliance frameworks, the new regime presents both heightened responsibility and strategic opportunity.

Author: Ms. Ammara Kazmi