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, bringing VASPs expressly into the UAE AML regime. Its parent regulation was repealed by Cabinet Resolution No. 134 of 2025, so this amendment is now historical.
Cabinet Resolution No. 24 of 2022 was the 2022 overhaul of the AML executive regulations (Cabinet Decision No. 10 of 2019). It is now historical: its parent regulation was repealed by Cabinet Resolution No. 134 of 2025, so nothing in it remains operative, although the Central Bank rulebook still displays it with the status in force. The rulebook's consolidated text of the 2019 regulation shows the pre-amendment wording as effective until 1 April 2022, which dates the amendment's practical effect to spring 2022.
The resolution has five clauses. Clause 1 replaced the wording of 22 articles of the 2019 regulation: Article 1 (new definitions of virtual assets, virtual asset service providers, legal arrangement, trust fund, real beneficiary, wire transfer and fictitious bank), Article 2 (17 categories of financial activity, adding stored value, digital payments and virtual banking), Article 4 (risk assessment), Articles 8 to 11 (identification, beneficial ownership at 25%, listed-company exemptions and insurance beneficiaries), Article 15 (politically exposed persons), Articles 17 to 19 (suspicious transaction reporting, tipping off and reliance on third parties), Articles 21 and 22 (compliance officer and high-risk countries), Article 24 (five-year record keeping), Article 27 (wire transfers at AED 3,500), Article 31 (group programmes), Article 37 (trustees), Article 42 (FIU), Article 44 (supervisory authorities) and Articles 51, 52 and 57 on international cooperation.
Clause 2 retitled Chapter 2 so that it covered financial institutions, DNFBPs, virtual asset service providers and non-profit organisations, and retitled Part 1 of Chapter 5 to refer to the supervisory authority for all three sectors. Clause 3 inserted a new Part 4, Virtual Asset Service Providers, with three articles: Article 33 bis (1) required anyone providing virtual asset services from the UAE to be licensed, enrolled or registered with the competent supervisory authority and required supervisors to detect and sanction unlicensed providers; Article 33 bis (2) required VASPs to assess and manage their risks; Article 33 bis (3) applied the regulation's CDD and record-keeping rules to VASPs, including CDD for occasional transactions of AED 3,500 or more and collection of originator and beneficiary data for transfers, extending the same to financial institutions handling virtual asset transfers.
Clause 4 cancelled conflicting provisions and Clause 5 brought the resolution into force the day after Official Gazette publication. The substance of Part 4 has been carried into Articles 4, 35 and 36 of Cabinet Resolution No. 134 of 2025. Status: superseded.
Historically, the financial institutions, DNFBPs and (from this amendment) virtual asset service providers covered by Cabinet Decision No. 10 of 2019, together with trustees, the FIU and the supervisory authorities. No longer operative following the repeal of the 2019 regulation by Cabinet Resolution No. 134 of 2025.
| Clause 1 | Replaces the wording of 22 articles of the 2019 regulation, including the definitions (adding virtual assets and VASPs), the financial activities list, risk assessment, identification and beneficial ownership, PEPs, reporting, tipping off, reliance on third parties, record keeping, wire transfers and supervisory duties. |
| Clause 2 | Retitles Chapter 2 to cover financial institutions, DNFBPs, virtual asset service providers and non-profit organisations, and Part 1 of Chapter 5 to name the supervisory authority for all three sectors. |
| Clause 3 | Inserts a new Part 4 entitled Virtual Asset Service Providers containing Articles 33 bis (1) to (3). |
| Article 33 bis (1) | Anyone providing virtual asset services from the UAE must be licensed, enrolled or registered with the competent supervisory authority, which must identify and sanction unlicensed providers and cooperate internationally. |
| Article 33 bis (2) | Virtual asset service providers must identify, assess, manage and mitigate their money laundering and terrorist financing risks under the Article 4 risk-assessment duty. |
| Article 33 bis (3) | Applies the regulation's CDD, reporting and record-keeping articles to VASPs, with CDD for occasional transactions of AED 3,500 or more and collection of originator and beneficiary information for transfers; also binds financial institutions handling virtual asset transfers. |
| Clause 4 | Every provision violating or contradicting the resolution is cancelled. |
| Clause 5 | Published in the Official Gazette and in force the day following publication. |
We read this resolution for history, not for current obligations. It explains two things our clients still see in documents dated 2022 to 2025: why bank and exchange onboarding questionnaires started asking about virtual asset exposure, and why the AED 3,500 CDD threshold applies to crypto transfers while fiat occasional transactions sit at AED 55,000. Both rules now live in Cabinet Resolution No. 134 of 2025, so when we update a client's AML manual we replace any citation of Article 33 bis with the 2025 article and keep the threshold. The rulebook's status label of in force for this amendment is misleading on its own; the instrument it amended no longer exists, and we say so when a client's previous adviser cites it as live law.
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