UAE Anti-Money Laundering, Terrorism, and Armament Financing Law 2025

The Riffle

The UAE has issued Federal Decree-Law No. (10) of 2025, establishing a significantly strengthened AML/CFT/CPF framework. The new law expands the scope of financial crimes—including Virtual Assets—enhances investigative powers, imposes stricter private-sector obligations, and introduces severe penalties for both individuals and legal persons. It reinforces governance structures, mandates robust compliance, and ensures international cooperation with no statute of limitations for ML/FT/PF offenses.

Key Highlights

1. Strengthened Governance Structure

• High-level High Committee (Presidential Court) and National Committee (Central Bank) to drive national AML/CFT strategy.

• FIU formally established within the Central Bank as the sole STR recipient.

• Supervisory Authorities empowered to inspect, enforce, and sanction FIs, DNFBPs, VASPs, and NPOs.

2. Expanded Scope & Clearer Definitions

• Virtual Assets, digital systems, and encryption explicitly covered.

• New standalone offense: Financing of Proliferation of Armaments (PF).

• Detailed definitions for Beneficial Owner, Predicate Offence, and Weapons of Mass Destruction.

3. Core Criminal Offenses

• Money Laundering: Any act of concealing, transferring, or using illicit proceeds — including through digital or VA channels.

• Terrorism Financing: Providing funds for terrorist acts or organisations, even from legal sources.

• Proliferation Financing: Funding activities linked to Weapons of Mass Destruction.

4. Private-Sector Obligations

• STRs: Mandatory immediate reporting to the FIU, overriding confidentiality.

• Risk-Based Approach: Ongoing risk identification, assessment & documentation.

• Due Diligence Measures: Customer and Beneficial Owner verification; continuous monitoring.

• No Anonymous Accounts: Numbered or fictitious accounts prohibited.

• TFS Compliance: Immediate implementation of Executive Office directives.

• Record Keeping: Retention & instant availability to authorities.

• Licensing: Mandatory for all FIs, DNFBPs, and VASPs.

5. Enhanced Investigative Powers

• FIU can suspend operations for 10 working days and freeze funds for 30 days without prior notification.

• Public Prosecutor and courts empowered to seize or freeze property urgently.

• LEAs can use undercover operations & controlled deliveries.

• Confiscation is mandatory upon conviction, including equivalent value.

6. Severe Penalties

• Individuals: Up to life imprisonment for FT; fines up to AED 10M.

• Legal Persons: Fines up to AED 100M; mandatory dissolution for FT/PF.

• Administrative penalties include warnings, multi-million-dirham fines, suspension, and license cancellation.

7. International Cooperation & Asset Recovery

• UAE must urgently execute international ML/FT/PF requests.

• No refusal based on confidentiality, tax, or customs matters.

• Foreign confiscation orders may be executed directly.

• Cabinet to establish a unified Asset Recovery framework.

8. Transitional Provisions

• Repeals the 2018 AML law; old regulations remain unless conflicting.

• Executive Regulations to follow.

• Good-faith reporting protected by Safe Harbour.

• No statute of limitations for ML, FT, or PF crimes.

What This Means for Regulated Entities

Federal Decree-Law No. (10) of 2025 marks a major shift in the UAE’s AML/CFT/CPF landscape. Entities must:

• Reassess AML/CFT/CPF frameworks immediately.

• Update risk assessments, DDM processes, and TFS screening systems.

• Strengthen internal controls, governance, and training.

• Ensure all STRs are filed promptly and accurately.

• Review licensing and registration obligations—especially VASPs and DNFBPs.

The message is clear: Vigilance, transparency, and strict compliance are now mandatory.

Read the full briefing document presented by 10 Leaves here -