Virtual assets: UAE legislation

Law No. 4 of 2022 Regulating Virtual Assets in the Emirate of Dubai

Establishes the Dubai Virtual Assets Regulatory Authority (VARA) as a public corporation affiliated with the Dubai World Trade Centre Authority and empowers it to license, regulate and supervise virtual asset activities and service providers across all zones of the Emirate, including special development zones and free zones, but excluding the DIFC. Effective on publication in the Official Gazette.

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. 99 of 2024 Concerning the List of Violations and Administrative Penalties for Acts Violating the Provisions of Cabinet Resolution No. 111 of 2022 Regulating Virtual Assets and its Service Providers

Sets the list of violations and administrative penalties the Securities and Commodities Authority may impose on virtual asset service providers and other persons breaching Cabinet Resolution No. 111 of 2022, including operating or promoting virtual asset services without a licence, breaching disclosure, governance or AML obligations, and the fines and licence measures for each.

Cabinet Resolution No. 111 of 2022 Regulating Virtual Assets and the Related Service Providers

The federal framework for virtual assets outside the financial free zones. It makes the Securities and Commodities Authority the federal licensing authority for virtual asset service providers, recognises local regulators such as Dubai's VARA, requires VASPs to be licensed and to comply with AML/CFT rules, and prohibits unlicensed virtual asset activity in the UAE.

Cabinet Resolution No. 24 of 2022 Amending Some Provisions of Cabinet Resolution No. 10 of 2019 on the Executive Regulations of Federal Decree-Law No. 20 of 2018 on Combating Money Laundering and the Financing of Terrorism and Illegal Organizations

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.

Federal Decree-Law No. 26 of 2021 Amending Certain Provisions of Federal Decree-Law No. 20 of 2018 on Anti-Money Laundering and Combating the Financing of Terrorism and Financing of Illegal Organisations

Rewrote large parts of the 2018 AML law: expanded definitions to cover virtual assets, virtual asset service providers and legal arrangements, strengthened FIU and supervisory powers, introduced administrative fines for supervised entities, raised criminal penalties and added Articles 16 bis, 25 bis and 26 bis. Its effect ended when the 2018 law was repealed in 2025.