Sanctions: UAE legislation

Ministry of Economy and Tourism Circular No. 1 of 2026 on Updating the Lists of High-Risk Countries, Countries Subject to Increased Monitoring, and Related Measures

Circular MOET/AML/001/2026 to real estate brokers, dealers in precious metals and stones, auditors, accountants and corporate services providers. It notifies National Committee Resolution No. 15 of 2025 updating the FATF high-risk and increased-monitoring lists, requires enhanced due diligence on relationships linked to those countries, bars branches, subsidiaries or third-party reliance in blacklisted countries, and recalls targeted financial sanctions duties.

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

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.

Federal Decree-Law No. 10 of 2025 Regarding Anti-Money Laundering, and Combating the Financing of Terrorism and Proliferation Financing

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).

Cabinet Resolution No. 71 of 2024 Regulating Violations and Administrative Penalties Imposed on Violators of Measures for Confronting Money Laundering and Combating Financing of Terrorism Subject to the Control of the Ministry of Justice and Ministry of Economy

Sets the schedule of administrative fines for DNFBPs supervised by the Ministry of Justice and the Ministry of Economy (lawyers, notaries, auditors, accountants, real estate brokers, dealers in precious metals and stones, and corporate service providers) that breach AML/CFT measures. Fines range from AED 50,000 to AED 1,000,000 per violation, doubled for repetition, replacing the 2021 unified list.

Cabinet Decision No. 74 of 2020 Regarding Terrorism Lists Regulation and Implementation of UN Security Council Resolutions on the Suppression and Combating of Terrorism, Terrorist Financing, Countering the Proliferation of Weapons of Mass Destruction and its Financing and Relevant Resolutions

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-Proliferation, immediate freezing without notice by financial institutions and DNFBPs, reporting of matches, grievances and access to frozen funds. Repealed Cabinet Decision No. 20 of 2019; still cited as current in 2026.

Anti-Money Laundering and Combating the Financing of Terrorism and Illegal Organisations – Guidelines for Designated Non-Financial Businesses and Professions (Version 6.0, April 2019)

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. It explains risk assessment, customer due diligence, beneficial ownership, suspicious transaction reporting, governance, record-keeping and sanctions compliance. Written under the 2018 law and 2019 regulation, both now repealed; no updated edition found officially.