Federal Decree-Law No. 20 of 2018 · UAE Federal
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 reporting. Amended in 2021 and 2024, it was repealed in full by Federal Decree-Law No. 10 of 2025 and is retained here because contracts, policies and guidance still cite it.
Federal Decree-Law No. 20 of 2018 was the UAE's anti-money laundering and counter-terrorist financing law from late 2018 until its repeal by Federal Decree-Law No. 10 of 2025. It is no longer in force. The Central Bank rulebook, which carries the consolidated English text, records it as effective from 23 October 2018 and shows the status banner confirming the 2025 repeal. It is kept in this library because client AML policies, bank onboarding forms, supervisory guidance and the 2019 DNFBP guidelines still cite it.
Article 2 defined money laundering as knowingly dealing with the proceeds of a felony or misdemeanour to conceal their source, acquire or use them, or help the offender escape punishment, made it an independent crime and removed any need for a conviction for the predicate offence. Article 3 covered financing of terrorism and illegal organisations. Article 9 placed an independent Financial Intelligence Unit inside the Central Bank, and Articles 12 and 12 bis created the National Committee and, from 2021, the Supreme Committee.
For regulated businesses the key articles were 13 to 16. Article 13 gave supervisory authorities risk assessment and inspection powers. Article 14 listed the administrative penalties: warnings, fines of no less than AED 50,000 and no more than AED 5,000,000 per violation, sector bans, restrictions on managers, removal of responsible individuals, activity restrictions and licence cancellation. Article 15 required suspicious transactions to be reported to the FIU without delay, with professional confidentiality no defence. Article 16 set the preventive duties: identify, assess, document and update crime risks, apply due diligence, refuse anonymous or fictitious accounts, adopt approved internal controls, implement UN Security Council measures immediately and keep records. Article 16 bis, added by Decree-Law No. 26 of 2021, required a licence or registration for virtual asset and financial activities.
Criminal penalties sat in Articles 22 to 29: up to ten years' imprisonment and AED 100,000 to AED 5,000,000 for money laundering, AED 300,000 to AED 10,000,000 in aggravated cases, life or at least ten years for terrorist financing, corporate fines of AED 500,000 to AED 50,000,000 with dissolution for terrorist financing, AED 100,000 to AED 1,000,000 for reporting breaches, at least one year and AED 100,000 to AED 500,000 for tipping off, and AED 200,000 to AED 5,000,000 under Article 26 bis for unlicensed activity. Article 29 required deportation of convicted foreigners and removed any limitation period.
Article 34 abrogated Federal Law No. 4 of 2002 and Article 35 brought the law into effect one month after Official Gazette publication. The law was amended by Decree-Law No. 26 of 2021 and Decree-Law No. 7 of 2024 before the 2025 law replaced it. The current position on every point above is now set by Decree-Law No. 10 of 2025.
Historically: financial institutions, designated non-financial businesses and professions as listed in the Executive Regulation (including trust and company service providers, auditors and real estate brokers), from 2021 virtual asset service providers, and any person in respect of the criminal offences. Since the 2025 repeal nobody is bound by this text; the same groups are bound by Federal Decree-Law No. 10 of 2025.
English official text in 35 articles. Open the full text or jump to a provision:
| Article 2 | Defined money laundering as knowingly dealing with the proceeds of a felony or misdemeanour to conceal, acquire or use them or help the offender escape punishment; made it an independent crime not requiring a predicate conviction. |
| Article 5 | Let the Central Bank Governor freeze suspicious funds for up to seven working days, renewable by the public prosecutor, and let prosecutors and courts freeze or seize assets without notice to the owner. |
| Article 9 | Established an independent Financial Intelligence Unit within the Central Bank to receive and analyse suspicious transaction reports and exchange information with domestic and foreign counterparts. |
| Article 14 | Administrative penalties for supervised entities: warnings, fines of no less than AED 50,000 and no more than AED 5,000,000 per violation, sector bans, restrictions on managers, removal of individuals, activity restrictions and licence cancellation. |
| Article 15 | Required financial institutions and DNFBPs to report suspicious transactions to the FIU without delay; confidentiality rules were no defence, with an exemption for lawyers and similar professionals where privilege applied. |
| Article 16 | Preventive duties: identify, assess, document and continuously update crime risks, apply due diligence, refuse anonymous or fictitious accounts, maintain approved internal controls, implement UN Security Council resolutions immediately and keep records. |
| Article 16 bis | Added by Decree-Law No. 26 of 2021: no person may carry on a virtual asset or financial activity without the required licence or registration. |
| Articles 22–23 | Money laundering: up to ten years and AED 100,000 to AED 5,000,000, rising to AED 300,000 to AED 10,000,000 in aggravated cases; terrorist financing: life or at least ten years; legal persons: AED 500,000 to AED 50,000,000 with dissolution for terrorist financing. |
| Articles 24–25 | Intentional or grossly negligent breach of reporting duties: imprisonment and/or AED 100,000 to AED 1,000,000; tipping off: at least one year and/or AED 100,000 to AED 500,000. |
| Article 29 | Foreigners convicted of money laundering were to be deported, and money laundering and terrorist financing offences had no limitation period. |
| Articles 34–35 | Abrogated Federal Law No. 4 of 2002 and conflicting provisions, and brought the Decree-Law into effect one month after publication in the Official Gazette. |
Historical only: Article 14 administrative fines of AED 50,000 to AED 5,000,000 per violation plus bans, restrictions and licence cancellation; Article 22 imprisonment of up to ten years and AED 100,000 to AED 5,000,000 for money laundering; Article 23 corporate fines of AED 500,000 to AED 50,000,000; Article 24 fines of AED 100,000 to AED 1,000,000 for reporting failures; Article 25 at least one year and AED 100,000 to AED 500,000 for tipping off; Article 26 bis AED 200,000 to AED 5,000,000 for unlicensed activity. All replaced by the penalty articles of Decree-Law No. 10 of 2025.
We still meet this law every week, not because it applies but because documents built on it are still in circulation. Client AML manuals drafted between 2019 and 2025, bank KYC questionnaires, free zone compliance declarations and the Ministry's DNFBP guidelines all cite Decree-Law 20 of 2018 and Cabinet Decision 10 of 2019. When we review or update a client's policy we replace those references with Decree-Law 10 of 2025 and Cabinet Resolution 134 of 2025, re-check the fine ranges and reporting wording against the new articles, and record the change in the policy's version history so an inspector sees that the programme was refreshed after the repeal. Our own AML/CFT/CPF policy went through the same exercise. Where an old document is still legally relevant, for example a historic breach being investigated, we keep the 2018 text to hand for the rules that applied at the time.
| Amended by | Federal Decree-Law No. 26 of 2021; Federal Decree-Law No. 7 of 2024 |
| Repeals | Federal Law No. 4 of 2002 |
| Repealed by | Federal Decree-Law No. 10 of 2025 |
| Cites | Financial Free Zones Law |
| Cited by | AML Implementing Regulation 2019 (repealed) · Beneficial Owner Procedures 2023 · Beneficial Owner Procedures 2020 (repealed) · Targeted Financial Sanctions Regulation · Federal Virtual Assets Regulation · UBO Administrative Penalties 2023 · AML Regulation Amendment 2022 (VASPs) · DNFBP AML Administrative Penalties 2024 · UAE DNFBP AML/CFT Guidelines · AML Law Amendment 2021 (historical) · KYC Digital Platform Law · Commercial Companies Law · Cybercrime Law · Commercial Transactions Law · Central Bank Law 2025 · IFZA Terms and Conditions · 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.
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