UAE’s New Anti-Money Laundering Law

The United Arab Emirates has put forward a major upgrade to its Anti-Money Laundering (AML) and counter-terrorism financing laws by introducing Federal Decree-Law No. 10 of 2025, which officially came into force on 14 October 2025. This new law replaced the existing law on AML i.e., the Federal Decree-Law No. 20 of 2018 and brings the country’s financial crime framework in line with international standards. The new law introduces a more expansive and sophisticated framework for anti-money laundering (AML) and counter-terrorism financing (CTF).

Changes introduced by the new legislation

Proliferation Financing

One of the most notable changes in the new AML law is the inclusion of proliferation financing within the scope of the law. The law now includes proliferation financing which means financing of weapons of mass destruction and arms proliferation, along with clear definitions for these terms and replaced the older focus on “Illegal Organisations.”

Provisions for Tax Evasion

The law also expands the definition of various offenses to include tax evasion, both direct and indirect, thereby expanding the types of criminal activity that can activate AML enforcement.

Inclusion of Digital Assets

The new law has been updated to reflect the realities of modern finance. Definitions of money laundering and terrorist financing are now openly including offenses committed through digital systems, virtual assets, and encryption technologies. This ensures that the law remains applicable in the context of emerging financial technologies.

‘Proceeds’ Redefined

Additionally, the definition of “Proceeds” has been redefined to include not only profits and economic advantages but also recurring and derivative benefits, closing loopholes that previously allowed certain gains from criminal property to escape from being scrutinised.

Criminal Intent

The standard for criminal intent has also been explained under the new law. Individuals can be held liable not only if they knowingly handle illicit funds but also if they should reasonably be aware of the criminal origin of those funds. Article 2(1) specifies that liability arises when there is sufficient evidence or indications of such knowledge.

Stronger Enforcement Mechanism

Enforcement mechanisms have been significantly strengthened under the new law. The Financial Information Unit (FIU) now has expanded powers under Article 5, including the authority to suspend transactions for up to ten working days and freeze funds for up to thirty days, with possible extensions by the Public Prosecutor. This is a notable shift from the 2018 law, where such powers were more limited and vested in the Governor of the Central Bank.

The new law also distinguishes between “Freezing” and “Seizure” of assets, providing clarity on the level of control and the implications of each measure. A Seizure order allows the competent authority to take control of assets for up to ten days, based on analysis of suspicious transaction reports or requests from national or international counterparts. In contrast, a Freezing order restricts the use of assets for up to thirty days but leaves them under the control of the original holder.

Provisions for Assets Recovery

A new Article 22 now provides a clear legal framework for recovering assets gained through criminal activity. It also includes protections for innocent third parties to ensure their rights are not affected.

Additionally, Article 6(3) makes any contract or deal invalid if it was made to hide or protect criminal assets from being seized, frozen, or confiscated, supporting a similar rule from the 2018 law. The law also raises financial penalties, linking them directly to the value of the criminal property, to make the punishment stronger and more effective as a deterrent.

For regulated entities such as banks, financial institutions, Designated Non-Financial Businesses and Professions (DNFBPs), and Virtual Asset Service Providers (VASPs), the new law sets stringent compliance standards.

Under Article 19 of the new law, continuous monitoring is now a clear and mandatory part of due diligence, going beyond the broader requirements in the previous law. The definition of a “Client” has also been widened to include anyone intending to start a business relationship, which means due diligence must now begin even before onboarding.

The law also looks ahead to future updates. Article 19(2) mentions that new executive regulations will soon offer more detailed guidance for a wider range of entities, including non-profit organizations, commercial registries, company managers, nominee shareholders, and trustees. Until those new rules are released, current regulations will continue to apply.

To conclude, Federal Decree-Law No. 10 of 2025 marks a major renovation of the UAE’s AML/CTF framework. It widens the scope of criminal liability, enhances enforcement powers, and aligns the country’s legal standards with international best practices. For the businesses operating in UAE, this means it is essential to proactively review and strengthen compliance programs to keep up with the new, more demanding and forward-looking regulatory landscape.