Federal Decree by Law No. (10) of 2025 Regarding Anti-Money Laundering, and Combating the Financing of Terrorism and Proliferation Financing
Federal Decree by Law No. (10) of 2025
The Decree-Law establishes the UAE federal framework for anti-money laundering, counter-terrorism financing and proliferation financing. It defines core offences, investigative and freezing powers, duties of regulated persons, national coordination mechanisms, enforcement measures and penalties, supported by Cabinet Resolution No. 134 of 2025 as its Executive Regulations.
Overview
What this legislation covers
The Decree-Law establishes the UAE federal framework for anti-money laundering, counter-terrorism financing and proliferation financing. It defines core offences, investigative and freezing powers, duties of regulated persons, national coordination mechanisms, enforcement measures and penalties, supported by Cabinet Resolution No. 134 of 2025 as its Executive Regulations.
Who or what it applies to
- Financial institutions regulated in the UAE.
- Designated non-financial businesses and professions within the statutory scope.
- Virtual-asset service providers within the statutory scope.
- Legal persons and natural persons involved in covered transactions or offences.
- Supervisory, law-enforcement, prosecution and financial-intelligence authorities.
Key points
Important points at a glance
Defines money laundering as an independent criminal offence.
Covers terrorism financing and proliferation financing, including relevant digital and virtual-asset channels.
Applies compliance duties to financial institutions, designated non-financial businesses and professions, and virtual-asset service providers.
Requires a risk-based approach, customer due diligence, ongoing monitoring and information retention.
Provides Financial Intelligence Unit powers to suspend suspicious transactions and temporarily freeze suspected funds.
Requires licensing, registration or enrolment for covered activities.
Establishes criminal liability and significant sanctions for legal persons in specified cases.
Provides a framework for targeted financial sanctions and beneficial-ownership information.
Creates judicial-enforcement and administrative-penalty mechanisms.
Cabinet Resolution No. 134 of 2025 supplies the current Executive Regulations.
Practical explanation
Understanding the law
Purpose and legislative background
The Decree-Law modernises the federal legal framework for preventing and prosecuting money laundering, terrorism financing and proliferation financing. It replaces Federal Decree by Law No. 20 of 2018 while preserving existing implementing instruments temporarily where they do not conflict, until replacement instruments are issued.
The principal implementing instrument verified in this research is Cabinet Resolution No. 134 of 2025, effective 14 December 2025. The Law and the Executive Regulations should therefore be read together.
Scope and who it applies to
The framework reaches natural and legal persons involved in the statutory offences and places preventive obligations on financial institutions, designated non-financial businesses and professions, virtual-asset service providers and other persons or arrangements addressed by the legislation. Supervisory authorities, the Financial Intelligence Unit, prosecution and law-enforcement authorities receive corresponding powers and duties.
Key definitions
The legislation uses specialised concepts such as predicate offence, proceeds, criminal property, beneficial owner, suspicious transaction, financial institution, DNFBP, virtual-asset service provider, targeted financial sanctions and competent/supervisory authority. These definitions determine the exact reach of duties and offences and should be checked before applying an obligation to a particular activity.
Main rights and obligations
- Carry out documented and continuously updated risk assessments.
- Apply customer due diligence and ongoing monitoring proportionate to risk.
- Maintain required records and make them available to the supervisory authority where required.
- Comply with suspicious-transaction reporting and related non-disclosure requirements.
- Comply with targeted financial sanctions and beneficial-ownership obligations.
- Do not conduct a covered regulated activity without the required licence, registration or enrolment.
Procedures and compliance
The Law establishes the high-level duties and powers; the Executive Regulations supply operational detail. Compliance teams should maintain a traceable mapping from internal procedures to the relevant statutory article and implementing provision, particularly for onboarding, ongoing monitoring, enhanced measures, correspondent relationships, wire transfers, beneficial ownership and record retention.
The Financial Intelligence Unit may order a short-term transaction suspension and may freeze suspected funds for the statutory period. Prosecution and courts have broader asset-tracing, seizure, freezing and protective powers.
Deadlines and time limits
Verified statutory time limits include the Financial Intelligence Unit power to suspend a transaction for up to 10 working days and freeze suspected funds for up to 30 days, subject to the legal extension mechanism. The Decree-Law entered into force two weeks after publication, on 14 October 2025. Other operational periods are governed by the detailed provisions and Executive Regulations and should be checked in the official text.
Enforcement, violations and penalties
The Decree-Law contains criminal sanctions for core offences and specific compliance breaches, corporate liability, confiscation-related measures, deportation provisions for specified foreign offenders, and a framework for administrative violations. Because the exact sanction depends on the article and factual classification, operational penalty tables should be taken directly from the official text and applicable Cabinet resolutions.
Practical scenarios
- A bank identifies activity inconsistent with a customer risk profile: its monitoring, escalation and reporting workflow should follow the Law and Executive Regulations without tipping off the customer.
- A virtual-asset business considers a new anonymity-enhancing service: licensing status, traceability and AML controls need review before launch.
- A corporate group uses nominee structures: beneficial-owner data must be accurate, retrievable and kept current under the applicable rules.
- A DNFBP receives a high-risk cross-border transaction: the risk assessment should drive enhanced controls and documented decision-making.
Amendments and related legislation
Federal Decree by Law No. 20 of 2018 is expressly repealed by Article 41. Cabinet Resolution No. 134 of 2025 is the verified Executive Regulations for the new Decree-Law and has been in force since 14 December 2025. Legacy resolutions and circulars may continue temporarily only to the extent the transitional rule permits and they do not conflict.
What businesses and individuals should check
- Whether the activity is a regulated financial activity, DNFBP activity or virtual-asset service activity.
- Whether licences, registrations and responsible officers are current.
- Whether enterprise and customer risk assessments reflect current products, geographies, channels and ownership structures.
- Whether beneficial-owner information and supporting evidence are accurate and current.
- Whether sanctions screening, transaction monitoring, escalation and reporting workflows are documented and tested.
- Whether policies cite the 2025 law and current Executive Regulations rather than superseded instruments.
When professional interpretation may be useful
Professional interpretation may be useful for complex beneficial-ownership structures, cross-border freezing or confiscation issues, regulator investigations, licensing perimeter questions, sanctions exposure, or determining how overlapping federal and free-zone requirements apply to a particular structure.
Practical notes
- Compliance programmes should be mapped to the 2025 Decree-Law and its 2025 Executive Regulations, not only the repealed 2018 framework.
- Customer, beneficial-owner and transaction-monitoring controls should be calibrated to documented risk assessments.
- Any operational use of penalty figures or freezing deadlines should be cross-checked against the official Arabic text and current implementing instruments.
Legislation text
Text and provisions
Source and language note: This file is a structured English rendering prepared for informational use from the legislation published through official UAE sources. It is not presented as the authoritative statutory text. For interpretation and application, the original Arabic legislation published by the UAE authorities controls; if there is any conflict, the Arabic text prevails.
The rendering below covers every numbered article identified in the verified legislative structure. It is designed for navigation and legal-information use; exact statutory wording, schedules, tables, monetary thresholds and exceptions must be checked against the linked official source.
Legislative structure and article-by-article rendering
Article (1) — Definitions
Defines the core terms used across the Decree-Law, including the State, Ministry, Central Bank, competent committees and authorities, financial institutions, designated non-financial businesses and professions, virtual-asset service providers, beneficial ownership, criminal property and related AML/CFT concepts.
Article (2) — Money Laundering
Defines money laundering as intentional dealing with proceeds of predicate offences through conversion, transfer, concealment, acquisition, possession, use, or assistance intended to disguise illicit origin or help an offender evade consequences. Money laundering is treated as an independent offence.
Article (3) — Financing of Terrorism and Proliferation Financing
Establishes the offences of financing terrorism and proliferation financing, including intentional provision, collection or making available of funds for prohibited purposes, including through digital systems, virtual assets or cryptographic technologies.
Article (4) — Criminal Liability of Legal Persons
Makes a legal person criminally liable where a covered crime is intentionally committed in its name or for its account, without excluding the personal liability of the natural person involved or applicable administrative penalties.
Article (5) — Temporary Suspension of Transactions and Freezing of Funds
Authorises the Financial Intelligence Unit chief, without prior notice and subject to statutory controls, to temporarily suspend a suspicious transaction for up to 10 working days and freeze suspected funds for up to 30 days, with extension of the freezing period by the Attorney General or delegate.
Article (6) — Provisional Measures by the Public Prosecution and Competent Court
Empowers the Public Prosecution and competent court to trace, value, seize or freeze relevant funds or criminal property and to impose protective measures while investigation or trial is pending; statutory grievance and procedural safeguards apply.
Article (7) — Management of Seized, Frozen or Confiscated Funds
Allows the prosecution or court to assign management of seized, frozen or confiscated assets, with the implementing regulation governing remuneration, expenses and detailed controls.
Article (8) — Criminal Proceedings, Protection Measures and Suspicious Transaction Reporting
Regulates commencement of criminal proceedings for the principal crimes, protective measures for intelligence and persons at risk, and the framework for suspicious-transaction reporting rules to be detailed by the Executive Regulations.
Article (9) — Additional Investigation and Asset-Control Measures
This article regulates additional investigation and asset-control measures within the statutory framework. The official text should be consulted for the precise conditions, exceptions, powers, procedural steps, thresholds and legal consequences attached to this subject.
Article (10) — Disclosure and Declarations
This article regulates disclosure and declarations within the statutory framework. The official text should be consulted for the precise conditions, exceptions, powers, procedural steps, thresholds and legal consequences attached to this subject.
Article (11) — Financial Intelligence Unit
This article regulates financial intelligence unit within the statutory framework. The official text should be consulted for the precise conditions, exceptions, powers, procedural steps, thresholds and legal consequences attached to this subject.
Article (12) — Supreme Committee
This article regulates supreme committee within the statutory framework. The official text should be consulted for the precise conditions, exceptions, powers, procedural steps, thresholds and legal consequences attached to this subject.
Article (13) — National Committee
This article regulates national committee within the statutory framework. The official text should be consulted for the precise conditions, exceptions, powers, procedural steps, thresholds and legal consequences attached to this subject.
Article (14) — Competences Supporting the National AML/CFT Framework
This article regulates competences supporting the national aml/cft framework within the statutory framework. The official text should be consulted for the precise conditions, exceptions, powers, procedural steps, thresholds and legal consequences attached to this subject.
Article (15) — National Coordination and Information Exchange
This article regulates national coordination and information exchange within the statutory framework. The official text should be consulted for the precise conditions, exceptions, powers, procedural steps, thresholds and legal consequences attached to this subject.
Article (16) — Supervisory Authorities
This article regulates supervisory authorities within the statutory framework. The official text should be consulted for the precise conditions, exceptions, powers, procedural steps, thresholds and legal consequences attached to this subject.
Article (17) — Risk-Based Supervision and Compliance Oversight
This article regulates risk-based supervision and compliance oversight within the statutory framework. The official text should be consulted for the precise conditions, exceptions, powers, procedural steps, thresholds and legal consequences attached to this subject.
Article (18) — Obligations and Regulatory Controls
This article regulates obligations and regulatory controls within the statutory framework. The official text should be consulted for the precise conditions, exceptions, powers, procedural steps, thresholds and legal consequences attached to this subject.
Article (19) — Obligations of Financial Institutions, DNFBPs and Virtual Asset Service Providers
Requires financial institutions, designated non-financial businesses and professions and virtual-asset service providers to identify, assess, document and update risks, apply customer due diligence and ongoing monitoring, retain information and comply with further obligations set by the Executive Regulations.
Article (20) — Licensing, Registration and Enrolment Requirement
Prohibits natural or legal persons from carrying on covered financial, designated non-financial or virtual-asset service activities without the required licence, registration or enrolment from the competent or supervisory authority.
Article (21) — International Cooperation and Exchange of Information
This article regulates international cooperation and exchange of information within the statutory framework. The official text should be consulted for the precise conditions, exceptions, powers, procedural steps, thresholds and legal consequences attached to this subject.
Article (22) — Cooperation on Requests and Measures
This article regulates cooperation on requests and measures within the statutory framework. The official text should be consulted for the precise conditions, exceptions, powers, procedural steps, thresholds and legal consequences attached to this subject.
Article (23) — Cross-Border and Competent-Authority Cooperation
This article regulates cross-border and competent-authority cooperation within the statutory framework. The official text should be consulted for the precise conditions, exceptions, powers, procedural steps, thresholds and legal consequences attached to this subject.
Article (24) — Additional Cooperation and Implementation Controls
This article regulates additional cooperation and implementation controls within the statutory framework. The official text should be consulted for the precise conditions, exceptions, powers, procedural steps, thresholds and legal consequences attached to this subject.
Article (25) — General Rule on Penalties
This article regulates general rule on penalties within the statutory framework. The official text should be consulted for the precise conditions, exceptions, powers, procedural steps, thresholds and legal consequences attached to this subject.
Article (26) — Penalties for Money Laundering, Terrorism Financing and Proliferation Financing
Sets the principal criminal penalties for money laundering and the financing offences. The precise ranges depend on the offence and aggravating circumstances; the official article should be consulted before relying on any sanction amount or custodial term.
Article (27) — Liability and Penalties of Legal Persons
Provides corporate penalties for legal persons whose representatives, directors or agents commit specified offences on their behalf or in their name, and also addresses management responsibility and possible dissolution or closure in specified cases.
Article (28) — Offence and Penalty Provision
This article regulates offence and penalty provision within the statutory framework. The official text should be consulted for the precise conditions, exceptions, powers, procedural steps, thresholds and legal consequences attached to this subject.
Article (29) — Offence and Penalty Provision
This article regulates offence and penalty provision within the statutory framework. The official text should be consulted for the precise conditions, exceptions, powers, procedural steps, thresholds and legal consequences attached to this subject.
Article (30) — Possession, Concealment and Anonymous Virtual-Asset Conduct
Criminalises specified dealings with funds where indicators point to illegitimate source or concealed beneficial ownership, and specified promotion or dealing in totally anonymous virtual-asset technologies that obstruct tracing, subject to the penalties stated in the official article.
Article (31) — Offence and Penalty Provision
This article regulates offence and penalty provision within the statutory framework. The official text should be consulted for the precise conditions, exceptions, powers, procedural steps, thresholds and legal consequences attached to this subject.
Article (32) — Unlicensed Regulated Activity
Creates a criminal penalty for violating the licensing, registration or enrolment requirement in Article 20.
Article (33) — Targeted Financial Sanctions Violations
Creates a criminal penalty for violating instructions relating to targeted financial sanctions issued by the Executive Office or another competent authority.
Article (34) — Disclosure and Information Violations
Penalises specified failures or misconduct concerning required disclosure or requested additional information, including deliberate concealment or knowingly false information.
Article (35) — Beneficial-Ownership, Account-Misuse and Compliance Violations
Addresses false or misleading beneficial-owner information, unlawful enabling of account misuse, and specified compliance failures under Article 19.
Article (36) — Deportation
Addresses deportation consequences for foreign nationals convicted and given custodial sentences for specified offences, distinguishing mandatory and discretionary cases.
Article (37) — Liability Protection, Limitation and Security Classification
Protects good-faith reporting and information provision by relevant authorities and regulated persons, addresses non-prescription of the principal offences and connected claims, and classifies specified offences as affecting State security.
Article (38) — Judicial Enforcement
Allows designated employees to be vested with judicial-enforcement powers for detecting contraventions under the Decree-Law and its implementing instruments.
Article (39) — Administrative Violations and Penalties
Requires a Cabinet resolution to prescribe administrative violations and penalties, responsible imposing authorities, grievance mechanisms and fine-collection arrangements.
Article (40) — Executive Regulations
Requires the Cabinet, on the Minister’s proposal, to issue the Executive Regulations.
Article (41) — Repeals
Repeals Federal Decree by Law No. 20 of 2018, repeals conflicting provisions, and preserves prior implementing instruments temporarily to the extent they do not conflict until replacements are issued.
Article (42) — Publication and Entry into Force
Requires publication in the Official Gazette and provides that the Decree-Law enters into force two weeks after publication.
Verification
Official source & references
Official legislation sourcehttps://uaelegislation.gov.ae/en/legislations/3314Open ↗This page is a research and educational resource. Legislation can be amended, repealed, supplemented by regulations or interpreted by courts and authorities. Obtain advice before relying on it for a live matter.