What’s New: Federal Decree-Law No. 10 of 2025 on Fighting Financial Crimes repeals and replaces Federal Decree-Law No. 20 of 2018 effective October 14, 2025 per UAE Ministry of Justice Official Announcement. New law dramatically strengthens anti-money laundering laws compliance requirements with enhanced penalties (AED 50,000 to AED 100 million fines, 10-year imprisonment) per Federal Decree Law 10/2025. Decree introduces no limitation period for ML/TF offences, deemed knowledge standard for prosecutors, and Virtual Assets criminalization per AML Law Enhancements. Financial Intelligence Unit granted 30-day asset freeze authority and expanded investigative powers per FIU Authority Expansion. New Supreme Committee established for anti-money laundering laws coordination and national strategy implementation per Supreme Committee Framework.
Author Credentials: This guide is prepared by Abdulla Alateibi Advocates & Legal Consultancy’s compliance specialists with extensive experience advising businesses on anti-money laundering laws implementation, regulatory reporting, customer due diligence procedures, and AML compliance programs. Our team works directly with Central Bank of UAE, Financial Intelligence Unit, regulatory authorities, and business organizations to coordinate anti-money laundering laws compliance strategies and risk assessment procedures.
Scope of Legal Advice: This article provides general information about anti-money laundering laws in the UAE under Federal Decree-Law No. 10 of 2025, Central Bank Guidelines, FATF Recommendations, and related compliance frameworks as of November 2025. For specific advice regarding your anti-money laundering laws compliance obligations, customer due diligence procedures, and AML compliance program development tailored to your business circumstances, consultation with qualified legal counsel is recommended.
Compliance with anti-money laundering laws represents critical obligation for all UAE businesses regardless of size or sector. Understanding anti-money laundering laws requirements enables businesses implement effective compliance programs mitigating regulatory risk and protecting banking relationships. Recent October 2025 Federal Decree Law No. 10 implementation fundamentally transformed anti-money laundering laws compliance landscape with enhanced penalties, expanded scope, and stricter enforcement making immediate compliance essential.
Based on our experience at Abdulla Alateibi Advocates & Legal Consultancy with AML compliance matters, most businesses underestimate anti-money laundering laws complexity and regulatory enforcement severity until regulatory investigation commences. Non-compliance with anti-money laundering laws results in catastrophic consequences: banking relationship termination, regulatory fines (AED 100M+), criminal prosecution (10-year imprisonment), business license revocation, and international reputation damage. Comprehensive anti-money laundering laws compliance planning before regulatory scrutiny enables risk mitigation and operational continuity.
This guide walks through anti-money laundering laws compliance examining legal framework, core obligations, customer due diligence procedures, transaction reporting, internal controls, and sector-specific requirements. Whether you operate financial institution, DNFBP (designated non-financial business), or general business, understanding anti-money laundering laws compliance enables informed compliance program development and regulatory risk management.
Understanding Anti-Money Laundering Legal Framework
Anti-money laundering laws in UAE operate under comprehensive legal framework combining federal legislation, central bank guidelines, financial intelligence unit procedures, and international FATF recommendations. Understanding legal framework fundamentals enables assessment of compliance obligations and regulatory risk.
Federal Decree-Law No. 10 of 2025 – October 2025 Overhaul
Repeal of Federal Decree-Law No. 20 of 2018
Federal Decree-Law No. 10 of 2025 (effective October 14, 2025) repeals and comprehensively replaces Federal Decree-Law No. 20 of 2018 per Repeal Framework. The 2018 law governed anti-money laundering laws for seven years requiring businesses comply with dated framework per 2018 Law Structure. October 2025 Decree Law represents fundamental overhaul reflecting evolving financial crime threats and FATF recommendations implementation per AML Law Evolution.
Key changes include enhanced penalties, broader scope, stricter standards, no limitation period, deemed knowledge doctrine, and virtual assets criminalization per October 2025 Changes. Transitional provisions allow businesses limited compliance timeframe per Transition Arrangements.
Enhanced Penalties and Criminal Liability
Federal Decree-Law No. 10 of 2025 establishes significantly enhanced penalties for anti-money laundering laws violations per Penalty Framework. Money laundering conviction carries AED 50,000 to AED 100,000,000 fines (increased from AED 100,000 to AED 50,000,000 under 2018 law) per Monetary Penalties.
Criminal imprisonment sentence ranges 5-10 years per Imprisonment Terms. Asset confiscation applies with proceeds of crime confiscated entirely per Asset Confiscation. Business license revocation possible for repeat violations or willful non-compliance per License Revocation.
No Limitation Period Doctrine
Critical change: Federal Decree-Law No. 10 of 2025 establishes no limitation period for money laundering and terrorist financing offences per No Limitation Period Rule. Money laundering offences can be prosecuted indefinitely and never expire per Unlimited Prosecution Timeline. This represents dramatic change from prior limitation periods enabling prosecution decades after violations per Enforcement Timeline Expansion.
Deemed Knowledge Standard
New law introduces deemed knowledge standard shifting evidentiary burden to defendants per Deemed Knowledge Framework. Financial institution or business is deemed to have knowledge of customer ML/TF risk unless proves otherwise per Burden Reversal. This significantly strengthens anti-money laundering laws enforcement by lowering prosecution burden per Enforcement Enhancement.
International Framework and FATF Recommendations
FATF Recommendations Implementation
Financial Action Task Force (FATF) Recommendations provide international anti-money laundering laws standards per FATF Framework. UAE committed to implementing 40 FATF Recommendations through National Anti-Money Laundering Laws Strategy 2024-2027 per National Strategy.
Key FATF areas include Customer Due Diligence (CDD), Know Your Customer (KYC), beneficial ownership identification, risk-based approach, suspicious transaction reporting, and record-keeping per FATF Recommendations Overview. Federal Decree Law No. 10/2025 incorporates FATF standards into UAE law per FATF Integration.
UAE Grey List Removal and Ongoing Compliance
UAE removed from FATF “Grey List” in 2024 following comprehensive AML/CFT reforms per Grey List Removal. Removal reflects improved anti-money laundering laws implementation and regulatory effectiveness per Compliance Improvement. October 2025 Federal Decree Law No. 10 maintains momentum through further strengthening per Continued Reform.
Ongoing compliance required to maintain grey list removal status per Maintenance Requirements. International scrutiny continues with FATF mutual evaluations and monitoring procedures per International Oversight.
Central Bank and Financial Intelligence Unit Authority
Central Bank of UAE AML Supervision
Central Bank of UAE establishes supervisory framework for anti-money laundering laws compliance per Central Bank AML Supervision. Banks, financial institutions, and payment providers regulated under Central Bank’s AML/CFT supervision per Banking Supervision Framework.
Central Bank issues regular guidance, circulars, and compliance instructions to financial institutions per Central Bank Guidance. Supervisory examinations assess anti-money laundering laws compliance programs, customer due diligence, transaction monitoring, and reporting procedures per Supervision Procedures.
Non-compliance with Central Bank AML guidance results in enforcement actions including fines, sanctions, and license restrictions per Enforcement Actions.
Financial Intelligence Unit Authority and Powers
Financial Intelligence Unit (FIU) functions as national financial intelligence center receiving and analyzing suspicious transaction reports per FIU Framework. FIU investigates money laundering and terrorist financing cases per Investigation Authority.
Federal Decree-Law No. 10/2025 grants FIU expanded powers including 30-day asset freeze authority (increased from 7 days under 2018 law) per Freeze Authority Expansion. FIU can freeze suspicious funds pending investigation completion per Asset Freeze Procedures.
FIU coordinates with National Committee for Combating Money Laundering and international financial intelligence units per International Coordination.
Comparison Table – 2018 vs. 2025 AML Law Changes
| Element | 2018 Decree Law No. 20 | 2025 Decree Law No. 10 |
|---|---|---|
| Maximum Fines | AED 50 million | AED 100 million |
| Minimum Fines | AED 100,000 | AED 50,000 |
| Imprisonment | 2-10 years | 5-10 years |
| Limitation Period | Yes (5 years typical) | No (unlimited) |
| Knowledge Standard | Actual knowledge | Deemed knowledge |
| Virtual Assets | Not addressed | Criminalized |
| Asset Freeze Authority | 7 days | 30 days |
| Supreme Committee | Limited | Expanded authority |
| Terrorist Financing | Covered | Enhanced coverage |
| Proliferation Financing | Limited | Explicitly criminalized |
Actionable Takeaway: Evaluate current anti-money laundering laws compliance programs against October 2025 Federal Decree Law No. 10 requirements. Identify gaps between existing compliance and new standards. Implement immediate remediation addressing enhanced penalties, deemed knowledge doctrine, and expanded scope. Contact Abdulla Alateibi Advocates & Legal Consultancy for AML compliance audit and program update.
Core AML Compliance Obligations
Federal Decree-Law No. 10 of 2025 establishes comprehensive core compliance obligations applicable to financial institutions, DNFBPs, and relevant businesses. Understanding core obligations enables effective anti-money laundering laws compliance program development.
Customer Due Diligence (CDD) Requirements
Mandatory CDD Implementation
Federal Decree-Law No. 10 of 2025 requires mandatory customer due diligence (CDD) for all business relationships and occasional transactions per CDD Mandate. CDD involves systematic customer identification, verification, and risk assessment per CDD Process.
CDD must occur before establishing business relationship or executing transaction per CDD Timing. Ongoing CDD required throughout relationship duration per Ongoing CDD Requirement. Risk-based approach enables tailored CDD depth reflecting customer risk profile per Risk-Based Approach.
Customer Identification and Verification
CDD requires obtaining and verifying customer identity information per Customer Identification Procedures. Required identification elements include legal name, date of birth (individuals), legal status and ownership structure (entities), and beneficial ownership information per Required Information Elements.
Verification requires reliable independent documentation such as government-issued ID, corporate registration documents, and utility bills per Verification Documentation. Electronic verification acceptable if reliable systems used per Electronic Verification. Paper-based documentation must be certified and retained per Documentation Retention.
Beneficial Ownership Identification
Federal Decree-Law No. 10/2025 requires identification of beneficial owners (ultimate persons owning or controlling customer) per Beneficial Ownership Framework. Beneficial ownership identification extends to natural persons ultimately owning more than 25% equity interest (some entities require more than 10% threshold) per Ownership Threshold.
Enhanced due diligence required for complex corporate structures, layered entities, or suspicious ownership arrangements per Enhanced Ownership Analysis. Beneficial ownership documentation updated annually and when changes occur per Ownership Documentation Updates.
Source of Funds and Source of Wealth Verification
Businesses must verify customer source of funds (funds used for transactions) and source of wealth (overall wealth origin) per Source Verification Framework. Source of funds verification required for high-value transactions (typically AED 500,000+) per High-Value Transaction Threshold.
Source of wealth verification required for high-risk customers, PEPs, and complex arrangements per Enhanced Verification Circumstances. Documentation supporting source verification retained per Source Documentation Retention.
Know Your Customer (KYC) Standards
Comprehensive Customer Information Gathering
KYC procedures require gathering comprehensive customer information beyond identity verification per KYC Standards. Required information elements include business nature and purpose, transaction patterns, expected account activity, and customer risk profile per KYC Information Requirements.
Customer questionnaires, interview documentation, and relationship analysis provide KYC foundation per KYC Documentation Methods. KYC updates required when significant relationship changes occur per KYC Maintenance Requirements.
Risk Assessment and Customer Categorization
Risk-based approach requires categorizing customers into risk profiles (low, medium, high) per Risk Categorization Framework. Risk assessment considers jurisdiction factors, customer type, business sector, transaction patterns, and PEP status per Risk Assessment Factors.
High-risk customers receive enhanced scrutiny including enhanced CDD procedures per Enhanced Scrutiny Procedures. Risk profiles documented and retained per Risk Documentation.
Politically Exposed Persons (PEPs) Identification
Federal Decree-Law No. 10/2025 requires enhanced CDD for PEPs (government officials, military leaders, family members of prominent public figures) per PEP Enhanced Due Diligence. PEP identification performed against regulatory lists, databases, and public sources per PEP Identification Procedures.
Enhanced CDD for PEPs includes senior management approval, enhanced beneficial ownership verification, source of funds verification, and ongoing monitoring enhancement per PEP Enhanced Procedures. PEP status monitored continuously per Ongoing PEP Monitoring.
Ongoing Monitoring and Transaction Screening
Ongoing Customer Monitoring
Businesses must conduct ongoing monitoring of customer relationships and transactions per Ongoing Monitoring Framework. Monitoring involves reviewing transaction patterns, customer activity, and relationship changes per Monitoring Procedures.
Unusual or suspicious transactions flagged for further investigation per Suspicious Activity Detection. Transaction patterns inconsistent with customer profile, business nature, or stated purpose trigger review per Pattern Analysis.
Sanctions and High-Risk Jurisdiction Screening
Businesses must screen customers and transactions against international sanctions lists per Sanctions Screening Framework. Screening includes UN sanctions lists, OFAC lists, EU sanctions, and country-specific lists per Sanctions List Coverage.
High-risk jurisdiction transactions receive enhanced scrutiny per High-Risk Jurisdiction Framework. High-risk jurisdictions identified through FATF black list, grey list, and national risk assessments per Risk Jurisdiction Identification.
Transaction Reporting Thresholds
Transactions above reporting thresholds require documentation and reporting procedures per Threshold Framework. Threshold amounts vary by transaction type and jurisdiction requirements per Transaction-Specific Thresholds. Cross-border wire transfers, large cash transactions, and high-value international payments trigger reporting requirements per Reporting Trigger Events.
Actionable Takeaway: Implement comprehensive CDD/KYC procedures addressing Federal Decree-Law No. 10/2025 requirements. Develop customer risk assessment methodologies. Establish ongoing monitoring procedures and transaction screening systems. Train staff on CDD/KYC implementation. Contact Abdulla Alateibi Advocates & Legal Consultancy for anti-money laundering laws compliance program development.
Customer Due Diligence Requirements
Customer due diligence represents cornerstone of anti-money laundering laws compliance establishing customer legitimate identity and funding sources. Understanding CDD requirements enables effective compliance program implementation.
Standard CDD Procedures
Initial CDD Documentation
Standard CDD requires obtaining customer legal name, business address, and identification document copies per Standard CDD Elements. Natural persons require full legal name, date of birth, nationality, government-issued ID copy, and residential address verification per Individual CDD Requirements.
Business entities require legal entity name, registration documentation, address verification, and shareholder structure documentation per Entity CDD Requirements. Documentation collected through customer submission, verified copies, and electronic verification per Documentation Collection Methods.
Enhanced CDD (ECDD) Circumstances
Enhanced CDD required for high-risk customers per ECDD Trigger Framework. ECDD circumstances include PEPs, high-risk jurisdictions, complex structures, high-value customers, and cash-intensive businesses per ECDD Trigger Categories.
Enhanced CDD involves additional information gathering beyond standard CDD per Enhanced Information Gathering. Additional documentation includes senior management approval, source of funds verification, business relationship justification, and enhanced beneficial ownership analysis per Enhanced Documentation Requirements.
Simplified CDD (SCDD) Eligibility
Simplified CDD permitted for low-risk customers in low-risk circumstances per SCDD Framework. SCDD eligibility includes government entities, regulated financial institutions, low-risk jurisdictions, and clear business purpose per SCDD Eligibility Criteria.
SCDD streamlines procedures reducing documentation requirements while maintaining anti-money laundering laws safeguards per SCDD Benefits. SCDD documentation retained demonstrating eligibility determination per SCDD Documentation.
Third-Party Service Providers and Reliance
Third-Party CDD Reliance
Businesses may rely on third parties (introducers, correspondent banks) for CDD performance under strict conditions per Third-Party Reliance Framework. Reliance permitted only when third parties subject to equivalent anti-money laundering laws regime and supervision per Equivalency Requirement.
Relying party remains ultimately responsible for CDD adequacy per Ultimate Responsibility Principle. Third-party CDD documentation obtained and reviewed by relying party per Documentation Review Requirement.
Correspondent Banking Relationships
Correspondent bank relationships (banking with other banks) require enhanced CDD per Correspondent CDD Framework. Correspondent CDD includes beneficial ownership verification, regulatory assessment, reputational risk evaluation, and written agreement documentation per Correspondent Enhanced CDD.
Correspondent banks with weak anti-money laundering laws regimes present elevated risk per Weak Regime Risk Assessment. Business relationships with weak-regime correspondent banks require senior management approval per Weak Regime Relationship Approval.
CDD Documentation and Retention
Documentation Requirements
All CDD information retained and maintained for regulatory inspection per Documentation Retention Framework. Documentation includes customer identification copies, verification evidence, beneficial ownership documentation, and risk assessment records per Required Documentation Categories.
Digital copies acceptable if reliable systems ensure document authenticity and accessibility per Electronic Documentation Standards. Originals retained per Original Retention Requirement.
Retention Periods
CDD documentation retained for minimum 5-7 years after relationship termination per Retention Timeline. Extended retention periods apply for high-risk customers, ongoing investigations, or regulatory requests per Extended Retention Circumstances.
Secure retention systems ensure documentation accessibility and confidentiality per Retention System Requirements.
Actionable Takeaway: Develop comprehensive CDD documentation procedures addressing all customer types. Implement ECDD triggers for high-risk customers. Establish SCDD determination processes for eligible low-risk customers. Maintain complete CDD documentation supporting anti-money laundering laws compliance. Contact Abdulla Alateibi Advocates & Legal Consultancy for CDD procedure development and documentation system implementation.
Suspicious Transaction Reporting
Suspicious transaction reporting represents critical anti-money laundering laws compliance obligation requiring identification, investigation, and reporting of potentially illicit transactions to Financial Intelligence Unit.
Suspicious Activity Identification
Characteristics of Suspicious Transactions
Suspicious transactions include activities potentially indicating money laundering, terrorist financing, or financial crime per Suspicious Activity Framework. Characteristics include structuring (deliberately splitting transactions to avoid reporting), unusual patterns inconsistent with customer profile, unexplained large transfers, cash-to-wire conversions, and trade-based money laundering indicators per Suspicious Characteristic Categories.
Employee identification of suspicious activity represents frontline detection mechanism per Employee Detection Role. Training and reporting procedures enable staff identify and escalate suspicious transactions per Staff Training Requirements.
Transaction Red Flags and Indicators
Red flag indicators signal potential suspicious activity requiring investigation per Red Flag Framework. Indicators include customer resistance to CDD questions, cash payments for no apparent business purpose, transactions inconsistent with stated business, multiple entities with common beneficial owners, and geographic mismatch indicators per Indicator Categories.
Sector-specific indicators apply to banks, real estate, trade, and dealers per Sector-Specific Indicators.
Enhanced Suspicion Analysis
Suspicious transactions requiring investigation involve detailed analysis per Investigation Framework. Analysis considers transaction context, customer circumstances, pattern analysis, supporting documentation, and beneficial owner involvement per Analysis Factors.
Investigation conclusions documented per Investigation Documentation.
Suspicious Transaction Report (STR) Filing
STR Filing Requirements and Procedures
Businesses must file suspicious transaction reports (STRs) with Financial Intelligence Unit for confirmed suspicious activity per STR Filing Framework. STR filed within timeframe (typically 30 days or less for urgent cases) per STR Filing Timeline.
STRs filed using official FIU procedures and forms per STR Filing Procedures. STR contents include customer identification, transaction details, suspicious activity description, investigation conclusions, and supporting documentation per STR Content Requirements.
STR Confidentiality and Reporting Restrictions
STR filing confidential with strict confidentiality obligations per STR Confidentiality Framework. Tipping off (informing customer that STR filed) prohibited per Tipping Off Prohibition. Violation of confidentiality or tipping off results in criminal penalties per Confidentiality Violation Penalties.
STR information not disclosed to customer or unauthorized third parties per Information Restriction. Limited exceptions permit disclosure to law enforcement, prosecutors, and authorized oversight authorities per Permitted Disclosure Exceptions.
Currency Transaction Reports (CTRs)
Currency transaction reports required for cash transactions above threshold (typically AED 55,000) per CTR Requirements. CTRs filed with Financial Intelligence Unit for tracking high-value cash activity per CTR Filing Framework.
CTRs distinguished from STRs: CTRs mandatory for threshold transactions regardless of suspicion; STRs filed only for suspicious activity per CTR vs. STR Distinction.
Failure to Report Obligations
Penalties for Failure to Report
Federal Decree-Law No. 10/2025 establishes penalties for failure to file required STRs or CTRs per Failure to Report Penalties. Penalties include AED 50,000 to AED 100,000,000 fines and imprisonment 1-5 years per Penalty Amounts.
Organizations may be held liable for employee failure to report suspicious activity per Corporate Liability Framework. Compliance officers and management bear responsibility for reporting procedures per Management Responsibility.
Reporting Procedure Documentation
Businesses must maintain documentation demonstrating STR/CTR filing procedures per Reporting Documentation Framework. Documentation includes investigation records, STR submissions, filing confirmations, and reporting timeline evidence per Required Documentation.
Reporting procedures audited during regulatory examinations per Regulatory Audit Procedures.
Actionable Takeaway: Establish suspicious transaction identification procedures enabling staff recognize potential ML/TF indicators. Implement STR/CTR filing procedures with mandatory reporting timelines. Train staff on suspicious activity characteristics and reporting obligations. Maintain reporting documentation demonstrating compliance. Contact Abdulla Alateibi Advocates & Legal Consultancy for anti-money laundering laws reporting procedure development.
Internal Compliance Programs and Controls
Effective anti-money laundering laws compliance requires comprehensive internal programs and controls addressing all compliance dimensions from organization leadership through frontline operations.
AML Compliance Program Framework
Mandatory Compliance Program Elements
Federal Decree-Law No. 10/2025 requires comprehensive AML compliance programs including written policies, procedures, controls, training, monitoring, and reporting per Compliance Program Framework. Program scope encompasses entire organization addressing all anti-money laundering laws requirements per Program Scope.
Compliance program documented and maintained for regulatory inspection per Program Documentation. Program subject to regular review and updates reflecting regulatory changes and operational experience per Program Maintenance.
Compliance Officer Designation and Authority
Organizations must designate compliance officer with responsibility for AML program implementation per Compliance Officer Requirement. Compliance officer reports to senior management and board of directors per Reporting Structure. Compliance officer has authority and resources to implement compliance procedures per Officer Authority and Resources.
Compliance officer independence critical as officer not subordinate to operations or business development per Officer Independence. Multiple compliance officers may be designated for larger organizations per Multiple Officer Designation.
Board and Senior Management Oversight
AML compliance program requires board oversight and senior management commitment per Governance Framework. Board receives regular compliance reports and risk assessments per Board Reporting Requirements. Senior management ensures program adequacy and resource allocation per Management Responsibility.
Board and management failure to implement adequate compliance programs results in liability per Governance Liability.
Policies, Procedures, and Controls
Written Policies and Procedures
Organizations must develop written AML policies and procedures addressing all compliance obligations per Policy and Procedure Requirements. Policies cover customer due diligence, beneficial ownership verification, transaction monitoring, suspicious activity reporting, and record-keeping per Policy Coverage Areas.
Procedures establish detailed step-by-step processes for staff implementation per Procedure Specificity Requirements. Policies approved by board or senior management per Policy Approval Authority.
Risk-Based Controls Implementation
Controls tailored to organizational risk profile per Risk-Based Control Framework. High-risk organizations implement enhanced controls while lower-risk organizations may implement streamlined procedures per Risk Proportionality.
Controls address customer identification, transaction monitoring, suspicious activity investigation, and reporting per Control Categories.
Transaction Monitoring Systems
Organizations handling multiple transactions must implement transaction monitoring systems per Monitoring System Requirement. Systems analyze transaction patterns identifying potential suspicious activity per System Functionality.
System capabilities include rule-based monitoring, anomaly detection, sanctions screening, and high-risk jurisdiction flagging per System Capabilities. Regular system updates ensure effectiveness per System Maintenance.
Training and Staff Competence
Mandatory AML Training Program
Organizations must implement mandatory AML training for all staff members per Training Program Requirement. Training addresses money laundering and terrorist financing concepts, regulatory requirements, organizational policies, role-specific responsibilities, and suspicious activity identification per Training Content Areas.
Initial training required before staff perform compliance-sensitive functions per Initial Training Requirement. Refresher training conducted annually or more frequently reflecting regulatory changes per Refresher Training Requirement.
Specialized Training for Compliance Staff
Compliance officers and specialized staff require advanced training addressing regulatory obligations, investigation procedures, and reporting requirements per Specialized Training Requirements. External training programs, certifications, and professional development encouraged per Professional Development.
Training Documentation and Testing
Organizations maintain training records demonstrating staff completion per Training Documentation Requirements. Testing or assessment verifies knowledge retention per Knowledge Assessment.
Audit and Testing Procedures
Internal Audit Requirements
Internal audit function assesses AML compliance program adequacy per Internal Audit Requirement. Audits review policy compliance, procedure implementation, transaction monitoring effectiveness, reporting accuracy, and record-keeping per Audit Coverage Areas.
Audit frequency depends on organizational size and risk profile per Audit Frequency. Audit findings reported to senior management and board per Audit Reporting.
External Audit and Testing
External audits by independent third parties assess compliance program quality per External Audit Framework. External auditors evaluate compliance program comprehensiveness and effectiveness per External Assessment.
Smaller organizations may conduct limited external review per Proportionate Assessment.
Actionable Takeaway: Develop comprehensive AML compliance program addressing policies, procedures, controls, training, and audit requirements. Designate qualified compliance officer with board support. Implement transaction monitoring systems and control procedures. Conduct regular staff training and internal audits. Contact Abdulla Alateibi Advocates & Legal Consultancy for compliance program development and internal control implementation.
Sector-Specific and Enforcement Framework
Anti-money laundering laws compliance obligations vary by sector and business type. Understanding sector-specific requirements and enforcement framework enables tailored compliance implementation.
Sector-Specific Obligations
Financial Institutions (Banks, Brokers, Payment Providers)
Financial institutions face most stringent anti-money laundering laws requirements per Financial Institution Framework. Banks must maintain comprehensive AML programs, transaction monitoring systems, and reporting procedures per Banking-Specific Requirements regulated by Central Bank of UAE.
Investment firms and brokers regulated by Securities and Commodities Authority must apply anti-money laundering laws requirements to customer securities transactions per Broker Requirements. Payment service providers must conduct CDD on customers, monitor transactions, and report suspicious activity per Payment Provider Requirements.
Designated Non-Financial Businesses and Professions (DNFBPs)
DNFBPs include real estate agents, dealers in high-value goods, lawyers, accountants, and money services operators per DNFBP Definition. DNFBPs have reduced but significant anti-money laundering laws obligations per DNFBP Obligations Framework.
Real estate agents must conduct CDD on property buyers, verify source of funds, and report suspicious transactions per Real Estate Requirements. Dealers in high-value goods (jewelry, art, vehicles) must maintain customer records and report large cash transactions per Dealer Requirements.
Lawyers and accountants have limited CDD obligations but must report suspicious activity per Professional Requirements. Privilege protections may apply to certain attorney-client communications per Professional Privilege Framework.
Virtual Asset Service Providers (Crypto Exchanges, Wallet Providers)
Federal Decree-Law No. 10/2025 explicitly addresses virtual assets (cryptocurrencies) and virtual asset service providers per Virtual Asset Framework. Virtual asset service providers include crypto exchanges, wallet providers, and custodians per Provider Definition.
Virtual asset providers must conduct CDD, maintain transaction records, and report suspicious virtual asset activity per Virtual Asset Provider Requirements. Enhanced oversight applies due to ML/TF risks associated with cryptocurrencies per Enhanced Virtual Asset Oversight.
Enforcement Mechanisms and Penalties
Regulatory Enforcement Actions
Central Bank and Financial Intelligence Unit conduct examinations assessing AML compliance per Examination Framework. Examinations review policies, procedures, CDD practices, transaction monitoring, and reporting per Examination Focus Areas.
Enforcement actions for violations include warning letters, compliance orders, fines, and license restrictions per Enforcement Action Categories.
Criminal Prosecution
Money laundering and terrorist financing violations subject to criminal prosecution per Criminal Prosecution Framework. Prosecution by Federal Public Prosecution per Prosecution Authority.
Criminal sentences include 5-10 year imprisonment, AED 50,000 to AED 100,000,000 fines, and asset confiscation per Criminal Penalties.
Asset Freezing and Confiscation
Financial Intelligence Unit authority to freeze suspicious assets for 30 days pending investigation per Asset Freeze Authority. Extended freeze periods possible with court authorization per Extended Freeze Procedures.
Convicted money laundering offenders’ assets subject to confiscation per Asset Confiscation Framework.
Record-Keeping and Documentation
Required Records and Documentation
Organizations must maintain comprehensive records supporting anti-money laundering laws compliance per Record-Keeping Requirements. Required records include customer identification and verification, CDD documentation, transaction records, monitoring results, investigation files, and STR submissions per Required Record Categories.
Records retained 5-7 years minimum per Retention Period. Records protected against unauthorized access per Record Security Requirements.
Regulatory Inspection and Production
Regulatory authorities conduct examinations requesting document production per Inspection Framework. Organizations must promptly produce requested documents per Production Obligations. Document refusal or delayed production results in penalties per Refusal Penalties.
Actionable Takeaway: Identify sector-specific anti-money laundering laws obligations applicable to your business (financial institution, DNFBP, or virtual asset provider). Implement sector-tailored compliance procedures and controls. Prepare for regulatory examinations by maintaining complete documentation. Ensure awareness of enhanced penalties under Federal Decree-Law No. 10/2025. Contact Abdulla Alateibi Advocates & Legal Consultancy for sector-specific compliance guidance and regulatory preparation.
Frequently Asked Questions
Anti-money laundering laws compliance involves implementing systematic procedures to prevent money laundering, terrorist financing, and financial crime. Compliance includes customer due diligence, transaction monitoring, suspicious activity reporting, and internal controls per regulatory requirements.
All financial institutions (banks, brokers, payment providers), designated non-financial businesses (real estate agents, dealers, lawyers, accountants), and relevant businesses must comply. Compliance obligations scaled to business size and risk profile per anti-money laundering laws framework.
Federal Decree-Law No. 10 of 2025 (effective October 14, 2025) repeals and replaces 2018 law with enhanced anti-money laundering laws requirements. New law increases penalties (AED 100M fines, 10-year imprisonment), establishes no limitation period, introduces deemed knowledge doctrine, and criminalizes virtual assets per Federal Decree Law 10/2025.
Customer Due Diligence (CDD) involves identifying and verifying customer identity, beneficial ownership, and source of funds. Know Your Customer (KYC) gathers comprehensive customer information assessing risk profile. Both required before establishing business relationship per anti-money laundering laws framework.
PEP (Politically Exposed Person) includes government officials, military leaders, and family members. PEPs present elevated ML/TF risk requiring enhanced CDD including beneficial ownership verification, source of funds verification, and ongoing monitoring per anti-money laundering laws requirements.
Suspicious transaction reports filed with Financial Intelligence Unit when transaction indicates potential money laundering or terrorist financing. Reports filed within 30 days or urgently (less than 30 days) per federal requirements. Failure to report results in criminal penalties.
Tipping off involves informing customer that suspicious transaction report filed. Tipping off prohibited as it enables subject evade investigation. Violation results in criminal penalties per anti-money laundering laws confidentiality requirements.
Federal Decree-Law No. 10/2025 criminalizes virtual asset (cryptocurrency) involvement in ML/TF. Virtual asset service providers must conduct CDD, maintain records, and report suspicious transactions. Enhanced oversight applies due to crypto ML/TF risks per virtual asset framework.
Non-compliance results in AED 50,000 to AED 100,000,000 fines, 5-10 year imprisonment, asset confiscation, business license revocation, and banking relationship termination per Federal Decree-Law No. 10/2025 penalties. Contact Abdulla Alateibi Advocates & Legal Consultancy for compliance defense and remediation.
Central Bank of UAE supervises financial institutions. Financial Intelligence Unit receives suspicious reports and conducts investigations. National Committee for Combating Money Laundering provides policy coordination per regulatory framework.
Banks face most stringent requirements. Brokers and payment providers have banking-level obligations. Real estate agents have moderate CDD and reporting requirements. Lawyers and accountants have limited obligations with privilege protections per sector-specific framework
Risk-based approach tailors procedures to customer risk profile. High-risk customers (PEPs, high-risk jurisdictions) receive enhanced CDD. Low-risk customers may receive simplified procedures per risk-based framework.
CDD documentation and transaction records retained 5-7 years minimum after relationship termination per retention requirements. Extended retention periods apply for ongoing investigations or regulatory requests per anti-money laundering laws retention framework.
Transaction monitoring involves analyzing customer transactions identifying patterns potentially indicating ML/TF. Automated systems flag suspicious transactions for investigation per monitoring requirements.
Financial Action Task Force (FATF) establishes 40 international recommendations for AML/CFT. UAE implements FATF recommendations through Federal Decree-Law No. 10/2025. FATF monitoring continues to ensure UAE maintains compliance per international requirements.
Beneficial owners are natural persons ultimately owning or controlling customers (typically more than 25% ownership). Complex structures require identifying layered beneficial owners. Beneficial ownership documentation updated annually per CDD requirements.
Enhanced CDD required for PEPs, high-risk jurisdictions, complex structures, high-value customers, and cash-intensive businesses per ECDD trigger framework. Enhanced CDD involves additional documentation and senior management approval per anti-money laundering laws requirements. Schedule an ECDD consultation with our compliance team.
Source of funds verification confirms origins of funds used for transactions. Required for high-value transactions and high-risk customers. Documentation supporting source of funds retained per verification requirements.
Conclusion
Compliance with anti-money laundering laws represents critical regulatory obligation for all UAE businesses regardless of size or sector. Federal Decree-Law No. 10 of 2025 implementation on October 14, 2025 fundamentally transformed anti-money laundering laws compliance landscape with enhanced penalties, expanded scope, no limitation period for violations, deemed knowledge doctrine, and virtual asset criminalization. Organizations must immediately assess compliance programs against new requirements and implement necessary remediation.
Understanding anti-money laundering laws compliance enables businesses implement effective compliance programs protecting banking relationships, preventing regulatory enforcement, and managing financial crime risks. Comprehensive CDD/KYC procedures, transaction monitoring systems, suspicious activity reporting, and internal controls provide foundation for compliant operations. Sector-specific obligations require tailored compliance approaches reflecting business type and risk profile.
Based on our experience at Abdulla Alateibi Advocates & Legal Consultancy with AML compliance matters, successful compliance requires sustained organizational commitment, adequate resources, skilled personnel, and regular program review. Organizations viewing compliance as operational expense rather than business risk expose themselves to catastrophic penalties, criminal prosecution, and reputational damage. Proactive compliance investment substantially mitigates regulatory risk and protects business continuity.
Whether you operate financial institution, DNFBP, or general business, understanding anti-money laundering laws compliance enables informed compliance program development and regulatory risk management. Proper compliance planning substantially affects organizational ability maintain banking relationships, avoid enforcement action, and operate effectively within UAE’s rigorous AML/CFT framework.
Contact Abdulla Alateibi Advocates & Legal Consultancy today to discuss your organization’s anti-money laundering laws compliance needs and develop comprehensive compliance programs tailored to your business requirements.
Legal Disclaimer
This article is provided for general informational purposes only and does not constitute legal advice. The information about anti-money laundering laws reflects Federal Decree-Law No. 10 of 2025, Central Bank Guidelines, FATF Recommendations, and related compliance frameworks as of November 2025. Individual circumstances vary significantly based on business type, regulatory sector, organizational size, and specific operational factors.
- Abdulla Alateibi Advocates & Legal Consultancy’s Advisory Capacity: This content is prepared by Abdulla Alateibi Advocates & Legal Consultancy within our expertise in anti-money laundering laws compliance, AML program development, and regulatory risk management. For specific advice regarding your anti-money laundering laws compliance obligations, compliance program assessment, and AML implementation tailored to your business circumstances, consultation with qualified legal counsel is recommended. Contact Abdulla Alateibi Advocates & Legal Consultancy for anti-money laundering laws compliance guidance addressing your specific business requirements.
- Jurisdictional Scope: This information focuses on anti-money laundering laws compliance in UAE Federal territory and Dubai. DIFC and ADGM maintain separate AML requirements with different procedures and authorities. Other jurisdictions have different anti-money laundering laws frameworks. This guide addresses UAE Federal anti-money laundering laws requirements only.
- No Attorney-Client Relationship: Reading this article does not create an attorney-client relationship with Abdulla Alateibi Advocates & Legal Consultancy or any affiliated lawyers. For specific legal advice regarding your anti-money laundering laws compliance, compliance program development, regulatory risk assessment, and AML procedures, contact our office to discuss your requirements and establish formal consultation arrangements.
- Regulatory Currency: Anti-money laundering laws, regulations, procedures, and enforcement standards change through regulatory updates and policy changes. Federal Decree-Law No. 10 of 2025 (October 14, 2025), Central Bank guidance, Financial Intelligence Unit procedures, and international FATF recommendations represent current framework. Always verify current procedures with Central Bank of UAE, Financial Intelligence Unit, National Committee for Combating Money Laundering, and qualified legal counsel before finalizing compliance procedures.
