On the 14 of October 2025, Federal Decree-Law No.10 of 2025 Regarding the Combating of Money Laundering Crimes, the Combating of the Financing of Terrorism, and the Financing of the Proliferation of Weapons (the “New AML Law”) came into effect. The New AML Law repeals and replaces Federal Decree Law No. 20 of 2018 (the “2018 Law”), reinforcing the UAE’s commitment to the Financial Action Task Force (FATF) objectives after being removed from the FATF grey list last year.
Key highlights of the New AML Law include an expanded scope that directly addresses virtual assets and proliferation financing, stronger supervisory and institutional architecture, earlier Financial Intelligence Unit (FIU) intervention powers, enhanced international cooperation and asset recovery, and a penalty framework calibrated to deter complex financial crime. Most notably the New AML Law lowers the evidential burden for establishing whether a money-laundering offence has been committed.
We summarise in this article some of these changes introduced by the New AML Law and how such changes may impact businesses within the region.
Expanded offences
The New AML Law introduces new categories of offences, including the criminalisation of arms and proliferation financing. Under the New AML Law, it is now illegal to finance without authorization, directly or indirectly, arms or weapons of mass destruction. Article 3 of the New AML Law states that anyone who makes funds available, including through the use of digital systems, virtual assets or encryption technologies, knowing that they will be used to finance terrorism, will have committed a terrorism financing offence.
The New AML Law also expands the scope of the types of activities which are considered a predicate crime. A predicate crime now includes both direct and indirect, tax evasion. The inclusion of direct and indirect tax evasion brings the UAE into closer alignment with international best practices and many other jurisdictions that capture tax evasion offences within their anti-money laundering legislation. In addition, the New AML Law introduces a structured taxonomy for criminal property, clarifying that confiscation, value-based orders and substitute assets may all be within scope where proceeds are mixed or otherwise unavailable.
Lowering the burden of proof
Under the 2018 Law, the burden of proof threshold to prove a money-laundering offence or terrorism finance offence had been committed was actual knowledge that the funds derived from a predicate offence. Under the New AML Law, Article 2 provides that knowledge can now be inferred where there is “sufficient evidence or circumstantial evidence”. This is a clear departure from the 2018 Law where an offence can now be committed if a person knew or could have known, that an offence would be committed. Whilst this is a clear departure from the 2018 Law, this is the threshold in many other jurisdictions such as the UK and many of the EU member states. We would expect that there is likely to be an increase in enforcement action taken by UAE authorities as a result of this change in position.
Institutional and supervisory enhancements
The New AML Law formalizes the relationships between the various UAE oversight bodies introduced under the 2018 Law. The New AML Law establishes a new Supreme Committee which is affiliated with the Presidential Court. The Supreme Committee is tasked with overseeing the National Committee, strategy efficacy, guiding the mutual evaluation process, and proposing legislative changes and budgetary measures. The National Committee, chaired by the Governor of the Central Bank of the UAE (the “CBUAE”), coordinates risk assessment, issues policy direction to supervisory authorities, and leads operational information-sharing across the system.
The FIU remains independent at the CBUAE, with clearer powers to request information, conclude cooperation arrangements, and operate secure databases with enhanced cyber controls. These adjustments formalise the governance reforms that underpinned the UAE’s progress since 2022 and more precisely allocate accountability for strategy, operations and oversight than under the 2018 Law.
A notable evolution from the 2018 Law is the empowerment of the FIU, who can now, without prior notice, freeze funds for up to 30 days (under the 2018 Law this was limited to 7 days), and this period can be extended further by the public prosector. Furthermore, the FIU can also suspend transactions without notice for up to 10 working days.
Federal and local law enforcement agencies have broader enforcement powers under the New AML Law and can access any information necessary to identify and track criminal property. The New AML Law also provides for court-approved arrangements for the management of frozen or seized assets, with fees, expenses and rules to be set in the executive regulations. This regime is better integrated and more time restricted than in the 2018 Law, with clearer value‑based alternatives where direct confiscation is impracticable.
The New AML Law also introduces a clear process on the appeals procedure for asset-freezing and interim orders which was lacking within the 2018 Law.
International cooperation
The New AML Law introduces a more facilitative process for cross-border cooperation than the 2018 Law. It removes traditional refusal bases, including tax and customs characterisation and most confidentiality claims, subject to protected legal privilege. The New AML Law also enables execution of foreign provisional and confiscation orders “without national investigations,” an efficiency step designed to expedite asset recovery where due process is met abroad. The competent authorities are required to prioritise and urgently execute requests and to exchange information automatically and on request, including between counterpart and non-counterpart authorities, with strict confidentiality limits on use.
Sanctions and penalties
One of the more notable changes within the New AML Law is the significant increase in penalties for offences committed.
For the offence of money laundering, it remains punishable by one to ten years’ imprisonment and the issuance of a fine, however, the New AML Law provides that the fine can now match up to the value of the criminal property, where such value is higher than the maximum stated fine. Where the money laundering offence is committed through a non-profit organization, an organized criminal group or the perpetrator is found to have exploited his influence by virtue of his job or professional activity, the fine can reach up to twice the value of the relevant criminal property.
For certain offences such as “tipping off”, there is no upper limit on the fines which can be imposed.
The New AML Law also introduces stricter penalties for legal entities if their representatives, managers or agents commit an offence under the law on their behalf or in their name with the maximum fine being AED 100 million. Under the 2018 Law this was previously capped at AED 50 million. Managers can also be held personally liable if they knew about the crime or the crime occurred as a result of a breach of their duties.
The doubling of the maximum fine from AED 50 million to AED 100 million under the New AML Law substantially raises the financial and reputational stakes for companies. This change reflects the UAE’s heightened emphasis on corporate accountability and governance in AML compliance. Companies will need to strengthen internal AML controls and oversight, review governance structures and enhance training and monitoring of staff. The explicit personal liability for managers adds further pressure on senior executives and board members to take an active role in the organisations AML compliance.
The New AML Law also introduces penalties to the new offences which have been brought in under the law, including:
- Possessing, concealing or conducting any transaction involving funds where there is sufficient evidence or circumstantial evidence of the illegality of its source or concealment of its true beneficiary; and
- Promoting, offering, providing or dealing in privacy enhancing virtual assets or technologies which prevent or hinder the ability of the authorities to track the transaction and its parties.
For both of these new offences, the penalty is 3-month imprisonment and a fine of no less than AED 50,000.
Implementing regulations
While the 2018 Law is expressly repealed, Article 41 of the New AML Law states its implementing executive regulations, decisions, and circulars continue to apply on an interim basis to the extent they do not conflict with the New AML Law, and until replacement instruments are issued. We therefore anticipate that new implementing regulations will be issued in due course to reflect the changes introduced by the New AML Law.
Concluding remarks
The New AML Law significantly strengthens the investigation and enforcement powers of both the UAE authorities and the AML oversight bodies. Both the reduction in the evidential burden from actual knowledge to inferred knowledge based on whether a person should have known and the sharp increase in fines and penalties paves the way for perhaps greater enforcement cases within the UAE. Whilst the implementing regulations of the 2018 Law remain in place, we anticipate these will be shortly amended or replaced to account for the various changes introduced by the New AML Law.
All businesses within the UAE and not just Financial Institutions, Designated Non-Financial Businesses and Professions and Virtual Asset Service Providers should ensure that their policies and procedures appropriately address the AML risks posed to their business. The changes introduced under the New AML Law signals a clear direction of travel, companies must embed a documented risk-based approach, strengthen beneficial ownership controls, clear and accountable governance structures and prepare for earlier actions from the AML oversight bodies.
