The UAE's principal AML law in 42 articles. It criminalises money laundering, terrorism and proliferation financing, imposes risk assessment, customer due diligence, record-keeping, sanctions-compliance and suspicious-transaction-reporting duties on financial institutions, DNFBPs and virtual asset service providers, creates the Supreme Committee and National Committee architecture, and repeals Federal Decree-Law No. 20 of 2018 (Article 41).
Federal Decree-Law No. 10 of 2025 is the UAE's current anti-money laundering, counter-terrorist financing and counter-proliferation financing law. It was issued on 30 September 2025, entered into force two weeks after publication in the Official Gazette (Article 42) and repealed Federal Decree-Law No. 20 of 2018 in full (Article 41), while keeping the earlier regulations and decisions in force where they do not conflict until they are replaced.
Article 2 treats money laundering as an independent crime: converting, transferring, concealing or acquiring the proceeds of a predicate offence, with knowledge inferred from the circumstances and no prior conviction for the predicate offence required. Article 3 criminalises financing terrorism and financing the proliferation of weapons of mass destruction. Article 4 makes a legal person criminally liable where a crime is committed in its name or for its account.
The preventive regime binds three groups: financial institutions, designated non-financial businesses and professions (DNFBPs, defined by reference to the activities listed in the Executive Regulations) and virtual asset service providers. Article 19 requires each of them to identify, assess, document and continuously update their risks of the crime, apply customer due diligence and ongoing monitoring scaled to risk, refuse anonymous or numbered accounts, maintain senior-management-approved internal controls extending to majority-owned branches and subsidiaries, apply targeted financial sanctions immediately, keep records and produce them to the authorities, and identify beneficial owners under the Cabinet's rules. Article 18 requires suspicious transactions to be reported to the Financial Intelligence Unit without delay and regardless of value. Article 20 prohibits carrying on a financial, DNFBP or VASP activity without a licence, registration or enrolment.
Article 11 keeps the FIU as an independent unit within the Central Bank receiving all suspicious transaction reports; under Article 5 its chief may suspend a transaction for up to ten working days and freeze funds for up to 30 days. Articles 12 to 15 set up the Higher Committee under the Presidential Court and the National Committee chaired by the Central Bank Governor, which sets the national strategy and identifies high-risk countries. Articles 16 and 17 give supervisory authorities inspection powers and an administrative toolkit: warnings, fines of AED 10,000 to AED 5,000,000 per violation, sector bans, restrictions on managers, suspension of staff, activity restrictions and licence revocation, with escalation for repeat violations within a year and publication of penalties.
Criminal penalties are in Articles 26 to 35: one to ten years' imprisonment and AED 100,000 to AED 5,000,000 for money laundering, higher bands for aggravated laundering, terrorism and proliferation financing, AED 5,000,000 to AED 100,000,000 for a legal person convicted of those offences, AED 100,000 to AED 1,000,000 for breaching reporting duties, at least AED 50,000 for tipping off, and AED 200,000 to AED 10,000,000 for unlicensed activity. Article 36 requires deportation of convicted foreigners and Article 37 removes any limitation period for these crimes.
Financial institutions, designated non-financial businesses and professions (including corporate service providers, auditors, accountants, real estate brokers and dealers in precious metals and stones as listed in the Executive Regulations), virtual asset service providers, their managers and staff, and non-profit organisations and company registrars with beneficial-ownership duties. It also binds any person in respect of the criminal offences and cross-border cash declarations.
| Article 2 | Defines the money laundering offence (converting, transferring, concealing, acquiring or helping evade punishment in respect of proceeds of a predicate offence), makes it an independent crime and allows knowledge to be inferred from the circumstances. |
| Article 3 | Criminalises providing or collecting funds for terrorist acts, terrorists or terrorist organisations, and financing the proliferation of weapons of mass destruction contrary to UN Security Council measures. |
| Article 4 | A legal person is criminally liable where a crime under the Decree-Law is committed in its name or for its account, without prejudice to the liability of individuals or to administrative penalties. |
| Article 5 | The FIU chief may suspend a transaction for not more than ten working days and freeze funds for not more than 30 days; prosecutors and courts may seize, freeze and trace assets. |
| Article 11 | Maintains an independent Financial Intelligence Unit within the Central Bank that receives and analyses all suspicious transaction reports from financial institutions, DNFBPs and VASPs and cooperates with domestic and foreign counterparts. |
| Article 17 | Supervisory authorities may impose warnings, administrative fines of AED 10,000 to AED 5,000,000 per violation, sector bans, restrictions on managers, suspension of personnel, activity restrictions and licence revocation, escalating for repeat violations within one year. |
| Article 18 | Financial institutions, DNFBPs and VASPs must report suspicions to the FIU without delay and regardless of value, and supply any further information requested; lawyers, notaries and auditors are exempt where professional secrecy applies. |
| Article 19 | Sets the preventive duties: documented and updated risk assessment, risk-based customer due diligence and ongoing monitoring, no anonymous or numbered accounts, approved internal controls across branches and subsidiaries, immediate targeted financial sanctions, record-keeping and beneficial-owner identification. |
| Article 20 | No person may carry on a financial, DNFBP or virtual asset service activity without the required licence, registration or enrolment. |
| Articles 26–27 | Money laundering: one to ten years' imprisonment and AED 100,000 to AED 5,000,000; terrorism financing: life or at least ten years and AED 1,000,000 to AED 10,000,000; legal persons: AED 5,000,000 to AED 100,000,000, with possible dissolution. |
| Articles 28–32 | Breach of reporting duties: imprisonment and/or AED 100,000 to AED 1,000,000; tipping off: imprisonment and/or at least AED 50,000; unlicensed activity under Article 20: imprisonment and/or AED 200,000 to AED 10,000,000. |
| Articles 41–42 | Repeals Federal Decree-Law No. 20 of 2018 and any conflicting provision, keeps existing regulations in force until replaced, and brings the Decree-Law into force two weeks after Official Gazette publication. |
Administrative: warnings, fines of AED 10,000 to AED 5,000,000 per violation, sector bans, restrictions on managers, staff suspension, activity restrictions and licence revocation, escalating for repeats within a year and publishable (Article 17). Criminal: one to ten years and AED 100,000 to AED 5,000,000 for money laundering; AED 1,000,000 to AED 10,000,000 bands for aggravated laundering, terrorism and proliferation financing; AED 5,000,000 to AED 100,000,000 for convicted legal persons; AED 100,000 to AED 1,000,000 for breaching reporting duties; at least AED 50,000 for tipping off; AED 200,000 to AED 10,000,000 for unlicensed activity (Articles 26 to 32). Mandatory confiscation and deportation of convicted foreigners (Articles 31 and 36).
We are a DNFBP under this law, with an appointed AML reporting officer and a goAML registration, so Article 19 is the backbone of our own onboarding: a documented enterprise risk assessment, risk-rated customer due diligence, beneficial-owner identification on every company we form or administer, immediate sanctions screening and record retention. Article 18 is why we will not delay or water down a suspicious transaction report, and Article 29 is why we never tell a client one has been filed. For clients, the law means every mainland, free zone and RAK ICC company must know who its beneficial owners are and be ready to prove it, and any client in a DNFBP or virtual asset activity must register with its supervisor and build the same programme. When we review client AML policies that still cite Decree-Law 20 of 2018, we map them to the 2025 articles and the new fine ranges.
AML Law 2018 (repealed)
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AML Executive Regulations 2025
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Targeted Financial Sanctions Regulation
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DNFBP AML Administrative Penalties 2024
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Beneficial Owner Procedures 2023
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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…
MoET Circular 1/2026 – High-Risk Jurisdictions
Circular MOET/AML/001/2026 to real estate brokers, dealers in precious metals and stones, auditors, accountants and corporate services providers. It notifies National Com…
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…
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