Federal Decree-Law No. (10) of 2025 on Combating Money Laundering, Terrorism Financing and Proliferation Financing took effect on 14 October 2025, repealing Federal Decree-Law No. (20) of 2018. Nearly twelve months on, the law is a central compliance concern for companies, financial institutions, designated non-financial businesses and professions (DNFBPs) and individuals, given its broader scope of criminalisation, tougher penalties and strengthened powers for supervisors and the Financial Intelligence Unit (FIU).
1. What the new law changes
The law makes proliferation financing a stand-alone offence alongside money laundering and terrorism financing, aligning UAE legislation with FATF standards. It also widens the concept of “proceeds” to cover any other benefits derived from the offence, not only direct profits, and states expressly that offences may be committed through digital systems, virtual assets or encryption technologies, language that did not appear in the previous law.
On proof, Article 2(3) provides that knowledge, intent or purpose may be inferred from factual and objective circumstances. In practice this eases the prosecution’s burden and makes ignoring red flags legally hazardous.
2. Obligations of regulated businesses and DNFBPs
Article 11 requires reporting entities to file suspicious transaction reports exclusively with the FIU. Reporting entities include financial institutions, virtual asset service providers and DNFBPs such as lawyers, accountants, real estate brokers, precious-metals dealers and corporate service providers. Article 19 makes continuous monitoring of customer relationships and risk profiles a distinct obligation, so due diligence at onboarding alone is no longer enough.
Under Article 5, the FIU may suspend suspicious transactions and freeze funds for limited periods pending action by the competent authorities. Businesses should therefore expect that a single suspicion can disrupt financial operations at short notice.
3. Penalties and liability
Penalties are tied to the value of the criminal property, and sanctions on legal persons are heavier. Published legal commentary points to corporate fines of between AED 5 million and AED 100 million, or an amount equal to the value of the property involved, together with possible licence revocation, suspension of activity and removal of executives. Managers and directors face imprisonment and/or fines, and misstating beneficial ownership attracts its own penalties. Article 27 addresses the criminal liability of legal persons without prejudice to that of individuals, while Article 37 provides that these offences are not subject to limitation periods.
Asset recovery is addressed in Article 22 and related provisions. Notably, UAE courts may enforce foreign confiscation orders, strengthening international judicial cooperation and limiting the ability of offenders to exploit multiple jurisdictions.
4. What companies should do now
Start by reviewing internal compliance policies and the enterprise-wide risk assessment against the new law. Update customer and beneficial-owner identification procedures, activate and document ongoing monitoring, train staff to recognise red flags and use the correct reporting channels, appoint a qualified compliance officer with real authority and independence, and keep records for the prescribed periods. Some implementation details, including beneficial ownership and corporate liability mechanics, depend on Cabinet regulations and resolutions, so businesses should follow those as they are issued.
AML compliance is no longer a secondary administrative matter; it is a core part of managing a business’s legal and reputational risk. Mohamed Al Azazi Advocates & Legal Consultants assists companies and individuals with compliance programme reviews, regulator requests and investigations in this area. This article is for general information only and is not legal advice on any specific situation.