The United Arab Emirates (UAE) has once again demonstrated its unwavering commitment to global financial security and compliance by enacting Federal Decree-Law No. 10 of 2025 regarding Combating Money Laundering Crimes, Combating the Financing of Terrorism (CFT), and the Financing of Arms Proliferation. This new legislation builds upon previous legal frameworks, introducing enhanced measures, broader scope, and significantly tougher penalties to solidify the UAE’s position as a robust, globally compliant economic hub.
Read more: A New Era of Financial Security: Understanding UAE Federal Decree-Law No. 10 of 2025 on Anti-Money LaunderingKey Provisions and Enhanced Compliance
Federal Decree-Law No. 10 of 2025 represents a comprehensive strengthening of the nation’s Anti-Money Laundering (AML) and CFT regime, closely aligning it with the latest recommendations from international bodies like the Financial Action Task Force (FATF).
- Expanded Scope and Obligated Entities
The law reaffirms and often expands the rigorous obligations on a wide range of entities, including:
- Financial Institutions (FIs): Banks, insurance companies, exchange houses, and other licensed financial services providers.
- Designated Non-Financial Businesses and Professions (DNFBPs): This crucial sector includes real estate brokers and agents, dealers in precious metals and gemstones, independent accountants and auditors, and trust and company service providers.
- Virtual Asset Service Providers (VASPs): The framework increasingly integrates the regulation of virtual assets, recognizing the emerging risks in this space.
These entities must adhere to core AML requirements, including Customer Due Diligence (CDD), Suspicious Transaction Reporting (STRs), Record-Keeping, and the implementation of a Risk-Based Approach (RBA).
- Sharper Investigative and Enforcement Tools
The Decree-Law equips authorities with greater power and clarity to investigate and prosecute financial crimes:
- Enhanced Investigative Powers: It explicitly grants law enforcement agencies and the Public Prosecution greater authority to obtain information, including third-party data and records, to effectively trace illicit financial flows.
- “Controlled Delivery” Principle: The law formalizes the use of “controlled delivery,” a technique that permits authorities to allow criminal transactions to proceed under supervision to trace their flow and identify the broader criminal network.
- Streamlined Asset Freezing: New mechanisms are introduced, potentially involving the Governor of the Central Bank, to expedite the freezing of suspected funds, minimizing the risk of asset dissipation.
Increased Penalties and Corporate Accountability
A defining feature of the new legislation is the significant increase in both financial and criminal penalties, serving as a powerful deterrent.
- Corporate Liability
The maximum penalties for legal persons (companies) have been notably raised:
- Administrative Fines: A fine no less than AED 500,000 and potentially not exceeding AED 50,000,000 can be imposed on a legal person whose representative, director, or agent commits a related crime.
- Compulsory Liquidation: In extreme cases, particularly those involving terrorist financing, the court may order the compulsory liquidation of the legal entity.
- Criminal Liability
For individuals convicted of money laundering:
- Repatriation for Foreigners: A foreigner convicted of an imprisonment sentence for money laundering or related felonies shall be repatriated from the UAE.
- Non-Lapse of Penal Claim: The penal claim for money laundering, financing terrorism, or financing illegal organizations shall not lapse by limitation (statute of limitations), emphasizing the permanent nature of the state’s pursuit of these crimes.
Implications for Businesses
The introduction of Federal Decree-Law No. 10 of 2025 signals that AML compliance is no longer a check-box exercise but a strategic imperative for any business operating in the UAE. Firms must proactively: - Review and Update Policies: Ensure their internal AML/CFT manuals, procedures, and controls are fully aligned with the requirements of the new Decree-Law and its Executive Regulations.
- Prioritize Training: Implement mandatory, regular AML/CFT training for all relevant employees, particularly those in compliance, sales, and senior management, to maintain a high level of awareness.
- Strengthen Technology: Invest in robust technological solutions, such as sophisticated transaction monitoring systems and tools for verifying Ultimate Beneficial Ownership (UBO), to effectively identify and mitigate risks.
This ambitious legislative update reinforces the UAE’s dedication to upholding the highest standards of financial integrity, ensuring that its economy remains both open for legitimate business and closed to illicit financial activities.