AML Executive Regulations 2025

Cabinet Resolution No. 134 of 2025 · UAE Federal

Official title
Cabinet Resolution No. 134 of 2025 Regarding the Executive Regulations of Federal Decree-Law No. 10 of 2025 Regarding Anti-Money Laundering, and Combating the Financing of Terrorism and Proliferation Financing
Instrument
Cabinet Resolution No. 134 of 2025
Issued by
UAE Cabinet
Jurisdiction
UAE Federal
Dates
issued 29 October 2025 · in force 14 December 2025
Status
in force
Topics
AML / CFT · Sanctions · Virtual assets
Official source
uaelegislation.gov.ae · official text (PDF)
Full text
English official text — 71 articles, 19,771 words, from the official text
Verified
25 October 2026
Print

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: business and customer risk assessment, standard, simplified and enhanced due diligence, beneficial owner identification, reliance on third parties, wire transfers, record-keeping, compliance officer duties, targeted financial sanctions and suspicious transaction reporting to the FIU.

Summary

Cabinet Resolution No. 134 of 2025 is the executive regulation of the 2025 AML law (Federal Decree-Law No. 10 of 2025). Issued on 29 October 2025, published in Official Gazette No. 811 on 14 November 2025 and effective from 14 December 2025, it replaces Cabinet Decision No. 10 of 2019 as the operative rulebook for financial institutions, DNFBPs and virtual asset service providers. It is the text our own AML programme and our clients' compliance frameworks are now written against.

Articles 2 to 4 define the obliged sectors. Article 3 lists the DNFBPs: gaming operators (AED 11,000 threshold), real estate agents, dealers in precious metals and stones for cash transactions of AED 55,000 or more, lawyers, notaries and accountants in specified transactions, and company and trust service providers when preparing or carrying out transactions for clients. Article 4 lists six virtual asset activities. Article 5 requires each institution to identify, assess and mitigate its risks, with enhanced measures for high risk and simplified measures permitted for low risk.

Articles 6 to 16 set customer due diligence: verification before or during the relationship (Article 6); triggers at onboarding, on suspicion, on doubt about data, and for occasional transactions of AED 55,000 or more or wire transfers of AED 3,500 or more, with VASPs applying CDD at AED 3,500 (Article 7); ongoing monitoring (Article 8); identification of natural persons, legal persons and arrangements (Article 9); beneficial ownership at 25% ownership, then control, then senior management (Article 10); a bar on continuing where CDD cannot be completed (Article 14); no shell banks or anonymous accounts (Article 15); and enhanced measures for foreign politically exposed persons (Article 16). Articles 17 to 19 cover suspicious activity indicators, immediate reporting to the FIU and the tipping-off prohibition. Article 20 governs reliance on third parties, Article 21 internal policies, Article 22 the compliance officer, Article 23 high-risk countries designated by the National Committee, Article 24 new technologies, and Article 25 retention of records for at least five years.

Articles 26 to 33 add financial-institution rules on correspondent banking, wire transfers and groups. Article 34 covers non-profit organisations; Articles 35 and 36 require VASPs to be licensed and to carry originator and beneficiary information with transfers. Articles 37 to 43 set beneficial ownership transparency: companies update basic and shareholder information within 15 working days, nominee directors and shareholders disclose their status, bearer shares are prohibited, and records are kept five years after dissolution. Articles 44 to 50 establish the FIU, the National Committee and the supervisory authorities; Articles 51 to 66 cover provisional measures, seizure, investigation and international cooperation.

Status: in force. The Central Bank rulebook records that this resolution repealed Cabinet Decision No. 10 of 2019; the repeal article sits beyond Article 66 and was not readable in the portal copy.

Who it applies to

Financial institutions listed in Article 2, the DNFBPs listed in Article 3 (gaming operators, real estate agents, dealers in precious metals and stones, lawyers, notaries, accountants and company and trust service providers such as Polaris), virtual asset service providers, non-profit organisations, registrars, companies and legal arrangements as to beneficial ownership, the FIU, the National Committee and the supervisory authorities.

Contents

English official text in 71 articles. Open the full text or jump to a provision:

  1. Article 1
  2. Article 2
  3. Article 3
  4. Article 4
  5. Article 5
  6. Article 6
  7. Article 7
  8. Article 8 — Financial Institutions, Designated Non-Financial Businesses and Professions, and Virtual
  9. Article 9
  10. Article 10 — Financial Institutions, Designated Non-Financial Businesses and Professions, and Virtual
  11. Article 11
  12. Article 12
  13. Article 13 — Financial Institutions, Designated Non-Financial Businesses and Professions, and Virtual
  14. Article 14
  15. Article 15 — Financial Institutions, Designated Non-Financial Businesses and Professions, and Virtual
  16. Article 16
  17. Article 17 — Financial Institutions, Designated Non-Financial Businesses and Professions, and Virtual
  18. Article 18
  19. Article 19
  20. Article 20
  21. Article 21 — Financial Institutions, Designated Non-Financial Businesses and Professions, and Virtual
  22. Article 22 — Financial Institutions, Designated Non-Financial Businesses and Professions, and Virtual
  23. Article 23
  24. Article 24
  25. Article 25
  26. Article 26
  27. Article 27
  28. Article 28
  29. Article 29
  30. Article 30
  31. Article 31
  32. Article 32
  33. Article 33
  34. Article 34
  35. Article 35
  36. Article 36
  37. Article 37
  38. Article 38
  39. Article 39
  40. Article 40
  41. Article 41
  42. Article 42
  43. Article 43
  44. Article 44
  45. Article 45
  46. Article 46
  47. Article 47
  48. Article 48
  49. Article 49
  50. Article 50
  51. Article 51
  52. Article 52
  53. Article 53
  54. Article 54
  55. Article 55
  56. Article 56
  57. Article 57
  58. Article 58
  59. Article 59
  60. Article 60
  61. Article 61
  62. Article 62
  63. Article 63
  64. Article 64
  65. Article 65
  66. Article 66
  67. Article 67
  68. Article 68
  69. Article 69
  70. Article 70
  71. Article 71

Key provisions

Article 3Lists the DNFBPs: gaming operators above AED 11,000, real estate agents, dealers in precious metals and stones for cash transactions of AED 55,000 or more, lawyers, notaries and accountants in specified transactions, and company and trust service providers acting for clients.
Article 5Each institution must identify, assess, document and mitigate its money laundering, terrorist financing and proliferation financing risks, applying enhanced measures to high risk and simplified measures only where risk is low.
Article 7CDD triggers: start of a business relationship, suspicion, doubt about earlier data, occasional transactions of AED 55,000 or more, wire transfers of AED 3,500 or more; VASPs apply CDD to occasional transactions of AED 3,500 or more.
Article 10Beneficial owner test: natural persons owning 25% or more of a legal person, failing that persons exercising control by other means, failing that the senior managing official; with parallel rules for settlors, trustees and beneficiaries of legal arrangements.
Article 14Where CDD cannot be completed the institution must not open the account or start the relationship and must consider filing a suspicious transaction report; CDD may be withheld where it would tip off the customer.
Article 16Politically exposed persons: risk systems to identify them, senior management approval, source of funds and wealth checks and enhanced monitoring for foreign PEPs, with risk-based measures for domestic and international-organisation PEPs.
Article 18Suspicious transactions must be reported to the FIU without delay and regardless of amount; lawyers, notaries and auditors are exempt for information covered by professional privilege.
Article 22The compliance officer monitors transactions, decides on reports to the FIU, reports to senior management, arranges training and cooperates with the supervisory authority.
Article 25All records, documents and data relating to domestic and international transactions and CDD must be retained for at least five years from the trigger date for each record type.
Article 36Virtual asset service providers must be licensed or registered, obtain and transmit originator and beneficiary information with transfers and apply targeted financial sanctions.
Article 38Companies must keep basic and shareholder information, update it within 15 working days, convert any bearer shares within 30 working days and cooperate with the authorities; nominee directors and shareholders disclose their status (Article 39).
Article 51The FIU Chief may suspend a transaction for up to ten working days and order a 30-day freeze of suspected funds as a provisional measure.

Obligations and deadlines

  • Document a business-wide risk assessment and keep it current (Article 5).
  • Verify customer and beneficial owner identity before or during onboarding and for occasional transactions of AED 55,000 or more (Articles 6, 7, 9, 10).
  • Apply enhanced due diligence to foreign PEPs and high-risk countries (Articles 16, 23).
  • Report suspicious transactions to the FIU without delay (Article 18) and never tip off (Article 19).
  • Appoint a compliance officer and maintain approved internal policies, screening, training and audit (Articles 21, 22).
  • Retain all transaction and CDD records for at least five years (Article 25).
  • Companies: update basic and shareholder information within 15 working days; no bearer shares (Article 38).

Penalties

The regulation refers administrative sanctions to the supervisory authorities (Article 49) and the schedules issued under Article 39 of the law. Under Federal Decree-Law No. 10 of 2025, supervisors may impose warnings, fines of AED 10,000 to AED 5,000,000 per violation, bans, management restrictions, suspension and licence revocation (Article 17); for DNFBPs under the Ministry of Economy and Tourism, Cabinet Resolution No. 71 of 2024 sets fines of AED 50,000 to AED 1,000,000 per violation, doubled for repetition.

In practice — how Polaris handles it

This is the rulebook our AML/CFT/CPF policy is written to, and the one we hand to our clients' compliance officers. Our onboarding file for every company we form or administer follows Articles 6 to 10: identity and address evidence for every natural person, the corporate chain down to the 25% beneficial owner, the purpose of the relationship, PEP and sanctions screening, and a risk rating that decides whether Article 16 enhanced measures or simplified measures apply. We refresh CDD on the schedule Article 8 requires, keep records for the five years Article 25 demands, and our compliance officer files any suspicious transaction report through goAML under Article 18. For clients who are themselves DNFBPs or VASPs we build the Article 21 policy set, the risk assessment and the training record, and we map every legacy reference to Cabinet Decision No. 10 of 2019 across to the new article numbers so a Ministry inspection sees a current framework.

History and citations

RepealsCabinet Decision No. 10 of 2019
CitesAML Implementing Regulation 2019 (repealed) · Emirates ID Law
Cited byADGM FSMR · MoET Circular 1/2026 – High-Risk Jurisdictions

“Cites” and “Cited by” are built automatically from references in the full texts held in this library; they cover only instruments in the library.

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Related Polaris services

Source and verification. This record was written from the official text published at uaelegislation.gov.ae, read on 25 October 2026. Quoted from that text: “Company and Trust Service Providers, when carrying out or executing any transaction for the benefit of”
Published for general information by Polaris Corporate Services FZ-LLC, a licensed Trust and Corporate Service Provider. It is not legal advice and does not replace the official text, which prevails in case of difference. Arabic is the authoritative language of UAE federal and emirate legislation; English translations are provided by the issuing authorities. Instruments change: check the status and the official source before relying on this page.

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