Cabinet Decision No. 10 of 2019 · UAE Federal
The former executive regulation of the 2018 AML law. It defined the DNFBP categories (including trust and company service providers), set customer due diligence, record-keeping and STR procedures, and was amended in 2022 to add a part on virtual asset service providers. Repealed by Cabinet Resolution No. 134 of 2025.
Cabinet Decision No. 10 of 2019 was the implementing regulation of the 2018 AML law (Federal Decree-Law No. 20 of 2018). It took effect on 10 February 2019, was substantially rewritten by Cabinet Resolution No. 24 of 2022, and has been repealed by Cabinet Resolution No. 134 of 2025, the executive regulations of the 2025 AML law. It stays in this library because goAML guidance, bank onboarding forms and many client AML manuals still cite it.
The regulation gave the law its operational content. Article 2 listed the financial activities that make a person a financial institution. Article 3 defined the designated non-financial businesses and professions (DNFBPs): real estate brokers and agents, dealers in precious metals and stones for cash transactions of AED 55,000 or more, lawyers, notaries and accountants acting in specified transactions, and corporate and trust service providers. Article 4 required every institution to assess its money laundering and terrorist financing risk, apply enhanced measures to high risk and, where permitted, simplified measures to low risk.
Articles 5 to 14 set the customer due diligence rules: verification before or during onboarding, CDD for occasional transactions of AED 55,000 or more and wire transfers of AED 3,500 or more (Article 6), ongoing monitoring (Article 7), identification of natural persons, legal persons and legal arrangements (Article 8), beneficial owner identification at 25% ownership with a control test and a senior-management fallback (Article 9), and a bar on dealing with shell banks or anonymous accounts (Article 14). Article 15 covered politically exposed persons, Articles 16 to 18 suspicious transaction reporting to the FIU and the tipping-off prohibition, Article 20 internal controls, Article 21 the compliance officer, and Article 24 a minimum five-year retention period for records.
The 2022 amendment added a Part 4 (Articles 33 bis 1 to 3) requiring virtual asset service providers to be licensed and to apply CDD to occasional transactions of AED 3,500 or more. Chapter 3 (Articles 34 to 39) dealt with registrars, shareholder registers, bearer shares and trustee disclosure; Chapters 4 and 5 with the FIU and the supervisory authorities.
Status: repealed. The Central Bank rulebook records the repeal by Cabinet Resolution No. 134 of 2025, which carries the same architecture forward under new article numbers (the DNFBP list is now Article 3 of the 2025 regulations and record-keeping is Article 25).
Historically, the financial institutions listed in Article 2, the DNFBPs listed in Article 3 (including corporate service providers such as Polaris), virtual asset service providers from 2022, registrars, trustees, non-profit organisations and the supervisory authorities. No longer binding on any of them; replaced by Cabinet Resolution No. 134 of 2025.
English official text in 62 articles. Open the full text or jump to a provision:
| Article 1 | Definitions, including the DNFBP definition as whoever conducts one or more of the commercial or professional activities listed in Article 3, and the definitions of real beneficiary, politically exposed persons and fictitious (shell) banks. |
| Article 3 | Lists the DNFBP categories: real estate brokers and agents, dealers in precious metals and stones for cash transactions of AED 55,000 or more, lawyers, notaries and accountants in specified transactions, and corporate and trust service providers, plus others set by ministerial decision. |
| Article 4 | Requires each institution to identify and assess its money laundering and terrorist financing risks, apply enhanced measures where risk is high and permits simplified measures where risk is low. |
| Article 6 | Sets the CDD triggers: new business relationships, occasional transactions of AED 55,000 or more, wire transfers of AED 3,500 or more, suspicion of crime, and doubts about previously obtained identification data. |
| Article 9 | Beneficial owner identification: any natural person owning or controlling 25% or more of a legal person, failing that any person exercising control by other means, failing that the senior managing official. |
| Article 17 | Requires prompt reporting of suspicious transactions to the FIU regardless of amount, with an exemption for lawyers and auditors bound by professional confidentiality and protection for good-faith reports. |
| Article 21 | Sets the compliance officer's duties: reviewing transactions and indicators, deciding on reports to the FIU, reporting to senior management, training staff and cooperating with the supervisory authority. |
| Article 24 | Records, documents and CDD data must be kept for no less than five years from completion of the transaction or end of the business relationship, in a form that allows reconstruction. |
| Articles 33 bis (1)–(3) | Added by Cabinet Resolution No. 24 of 2022: virtual asset service providers must be licensed or registered, assess their own risks, apply the regulation's CDD rules to occasional transactions of AED 3,500 or more and keep originator and beneficiary data for transfers. |
| Article 44 | Lists the supervisory authorities' duties, including risk-based on-site and off-site supervision, fit-and-proper standards for owners and managers, maintaining the list of compliance officers and issuing administrative sanctions with a complaint procedure. |
The regulation itself set no fine amounts. Article 44 tasked each supervisory authority with issuing administrative sanctions and a complaint procedure; the sanctions and ranges came from the 2018 law (Article 14: AED 50,000 to AED 5,000,000 per violation) and the Cabinet fine schedules, now Cabinet Resolution No. 71 of 2024 for DNFBPs supervised by the Ministry of Economy and Tourism.
We still meet this regulation every week, even though it is repealed. Bank KYC questionnaires, the goAML registration page and most of the AML manuals our clients inherited from previous providers cite Article 3 of Cabinet Decision No. 10 of 2019 as the source of the DNFBP definition and Article 20(2) as the basis for goAML registration. When we review or rebuild a client's AML policy we map every such reference to the equivalent article of Cabinet Resolution No. 134 of 2025 and to Federal Decree-Law No. 10 of 2025, and we record the date of the change in the policy's version history so a supervisor can see the update. The substantive thresholds our clients know (AED 55,000 for occasional transactions, AED 3,500 for wire transfers, 25% for beneficial ownership, five-year retention) have carried over, so the practical workflow rarely changes; the citations do.
| Amended by | Cabinet Resolution No. 24 of 2022 |
| Repealed by | Cabinet Resolution No. 134 of 2025 |
| Cites | AML Law 2018 (repealed) |
| Cited by | Beneficial Owner Procedures 2023 · Beneficial Owner Procedures 2020 (repealed) · UBO Administrative Penalties 2023 · AML Executive Regulations 2025 · AML Regulation Amendment 2022 (VASPs) · DNFBP AML Administrative Penalties 2024 · CBUAE AML/CFT Procedures Decision · UAE DNFBP AML/CFT Guidelines · IFZA Terms and Conditions · goAML Registration Rules (DNFBPs) · RAKEZ CSP Regulations 2020 |
“Cites” and “Cited by” are built automatically from references in the full texts held in this library; they cover only instruments in the library.
AML Law 2018 (repealed)
The former UAE AML/CFT law, in force from October 2018, which first brought designated non-financial businesses and professions under federal AML supervision and goAML re…
AML Regulation Amendment 2022 (VASPs)
Replaced the wording of most articles of the 2019 AML implementing regulation, retitled its second chapter and added a new fourth part on Virtual Asset Service Providers,…
AML Executive Regulations 2025
The executive regulations of the 2025 AML law, replacing Cabinet Decision No. 10 of 2019. They set the detailed requirements for financial institutions, DNFBPs and VASPs:…
AML/CFT/CPF Law 2025
The UAE's principal AML law in 42 articles. It criminalises money laundering, terrorism and proliferation financing, imposes risk assessment, customer due diligence, reco…
DNFBP AML Administrative Penalties 2024
Sets the schedule of administrative fines for DNFBPs supervised by the Ministry of Justice and the Ministry of Economy (lawyers, notaries, auditors, accountants, real est…
Targeted Financial Sanctions Regulation
Governs the UAE Local Terrorist List and the implementation of UN Security Council sanctions: listing and delisting, the role of the Executive Office for Control and Non-…
UAE DNFBP AML/CFT Guidelines
Joint guidance of the UAE supervisory authorities for auditors, lawyers, company and trust service providers, dealers in precious metals and stones and real estate agents…
goAML Registration Rules (DNFBPs)
The Ministry's official page and step-by-step guide on mandatory goAML registration for the DNFBPs it supervises: real estate brokers, auditors and accountants, dealers i…
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