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The UAE adopts a new anti-money laundering Law

On 30 September, the United Arab Emirates (UAE) adopted a new anti-money laundering (AML) law (Federal Decree-Law No. 10 of 2025), which, replaces the previous 2018 law. This revamp is part of the country’s ongoing efforts to strengthen its framework against financial crime, align with international standards set by the Financial Action Task Force (FATF), and reflect its goal of positioning itself as a secure and attractive hub for business and finance. 



  • Expanded scope of offences:
 The new law modernizes and broadens the definition of financial crimes to address evolving threats. 
 Proliferation financing: Introduces new offenses that criminalize the unauthorized financing of arms and weapons of mass destruction.
  • Digital and virtual assets: Expands the scope of the law to expressly cover the use of digital systems, virtual assets, and encryption technologies for money laundering and terrorist financing.


  • Tax evasion: Adds direct and indirect tax evasion to the list of predicate offenses that can be linked to money laundering. 


  • Lowered burden of proof:
 Inferred knowledge: Prosecutors no longer need to prove actual knowledge of criminal proceeds. Instead, knowledge can be inferred from “sufficient evidence or circumstantial evidence,” aligning the UAE’s standard with other major jurisdictions. 


  • Stronger institutional and supervisory framework:
 The government has restructured its AML oversight bodies to improve coordination and enforcement.


Supreme Committee: a new Supreme Committee, under the authority of the Presidential Court, now oversees the national strategy.


  • National Committee: implements and coordinates the national AML strategy.

  • Empowered FIU: The Financial Intelligence Unit (FIU) has been granted greater powers, including the authority to freeze funds for up to 30 days and suspend transactions for up to 10 days without prior notice. 

 Increased penalties
 The law introduces significantly higher financial penalties for non-compliance for both companies and individuals. 


  • Enhanced international cooperation
 Expedited recovery: The law makes it easier to enforce foreign judgments and seize and confiscate criminal proceeds, even without a local investigation. 

 Impact on businesses
 The new legislation places greater responsibility and scrutiny on businesses operating in the UAE, particularly financial institutions and Designated Non-Financial Businesses and Professions (DNFBPs), such as lawyers, real estate brokers and dealers in precious metals. 

  • They must now: Review and update internal AML policies, procedures and controls to address the expanded scope of offenses, including virtual assets and tax evasion.

  • Update governance structures: Prepare for increased personal liability for managers and ensure transparent and accountable governance.

  • Expect more enforcement: Brace for an increase in proactive investigations and enforcement actions from regulatory bodies.
On 30 September, the United Arab Emirates (UAE) adopted a new anti-money laundering (AML) law (Federal Decree-Law No. 10 of 2025), which, replaces the previous 2018 law. This revamp is part of the country’s ongoing efforts to strengthen its framework against financial crime, align with international standards set by the Financial Action Task Force (FATF), and reflect its goal of positioning itself as a secure and attractive hub for business and finance. 

 * Expanded scope of offences:
 The new law modernizes and broadens the definition of financial crimes to address evolving threats. 
 Proliferation financing: Introduces new offenses that criminalize the unauthorized financing of arms and weapons of mass destruction.

 * Digital and virtual assets: Expands the scope of the law to expressly cover the use of digital systems, virtual assets, and encryption technologies for money laundering and terrorist financing.

 * Tax evasion: Adds direct and indirect tax evasion to the list of predicate offenses that can be linked to money laundering. 

 * Lowered burden of proof:
 Inferred knowledge: Prosecutors no longer need to prove actual knowledge of criminal proceeds. Instead, knowledge can be inferred from “sufficient evidence or circumstantial evidence,” aligning the UAE’s standard with other major jurisdictions. 

 * Stronger institutional and supervisory framework:
 The government has restructured its AML oversight bodies to improve coordination and enforcement. 
 Supreme Committee: a new Supreme Committee, under the authority of the Presidential Court, now oversees the national strategy. 
 * National Committee: implements and coordinates the national AML strategy. 
 * Empowered FIU: The Financial Intelligence Unit (FIU) has been granted greater powers, including the authority to freeze funds for up to 30 days and suspend transactions for up to 10 days without prior notice. 

 Increased penalties
 The law introduces significantly higher financial penalties for non-compliance for both companies and individuals. 

 * Enhanced international cooperation
 Expedited recovery: The law makes it easier to enforce foreign judgments and seize and confiscate criminal proceeds, even without a local investigation. 

 Impact on businesses
 The new legislation places greater responsibility and scrutiny on businesses operating in the UAE, particularly financial institutions and Designated Non-Financial Businesses and Professions (DNFBPs), such as lawyers, real estate brokers and dealers in precious metals. 
 * They must now: Review and update internal AML policies, procedures and controls to address the expanded scope of offenses, including virtual assets and tax evasion. 
 * Update governance structures: Prepare for increased personal liability for managers and ensure transparent and accountable governance. 
 * Expect more enforcement: Brace for an increase in proactive investigations and enforcement actions from regulatory bodies.