Cabinet Resolution No. 134 of 2025 · UAE Federal
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.
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.
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.
English official text in 71 articles. Open the full text or jump to a provision:
| Article 3 | Lists 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 5 | Each 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 7 | CDD 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 10 | Beneficial 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 14 | Where 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 16 | Politically 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 18 | Suspicious 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 22 | The compliance officer monitors transactions, decides on reports to the FIU, reports to senior management, arranges training and cooperates with the supervisory authority. |
| Article 25 | All 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 36 | Virtual asset service providers must be licensed or registered, obtain and transmit originator and beneficiary information with transfers and apply targeted financial sanctions. |
| Article 38 | Companies 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 51 | The 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. |
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.
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.
| Repeals | Cabinet Decision No. 10 of 2019 |
| Cites | AML Implementing Regulation 2019 (repealed) · Emirates ID Law |
| Cited by | ADGM 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.
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…
AML Implementing Regulation 2019 (repealed)
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-k…
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,…
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-…
Beneficial Owner Procedures 2023
The current UAE beneficial ownership regime, replacing Cabinet Decision No. 58 of 2020. Companies licensed in the mainland and in non-financial free zones must identify t…
Federal Virtual Assets Regulation
The federal framework for virtual assets outside the financial free zones. It makes the Securities and Commodities Authority the federal licensing authority for virtual a…
MoET Circular 6/2025 – Risk-Based CDD
Circular MOET/AML/6/2025 directing DNFBPs under Ministry supervision to scale customer due diligence to risk: enhanced due diligence for high-risk customers, standard mea…
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