Key Highlights of the Core Changes Introduced by UAE AML/CFT Law No. 10 of 2025

The UAE has introduced a significantly strengthened Anti-Money Laundering and Counter-Terrorist Financing framework through Federal Decree-Law No. 10 of 2025, which repeals and replaces the previous AML legislation issued in 2018. The new law materially expands regulatory oversight, enforcement powers, and penalty thresholds, while introducing new criminal classifications, most notably Proliferation Financing.

The law came into effect on 14 October 2025. Its Executive Regulations, issued under Cabinet Resolution No. 134 of 2025, will apply from 14 December 2025.

Among the most notable developments are:

-Explicit regulation of Virtual Assets and Virtual Asset Service Providers (VASPs), including licensing, transaction monitoring, reporting obligations, and enhanced oversight of cryptographic and blockchain-based technologies.

-Increased regulatory scrutiny of Beneficial Ownership disclosures, Suspicious Transaction Reporting (STR), sanctions screening, and enterprise-wide risk assessments.

-Expanded powers of the Financial Intelligence Unit (FIU), including broader authority to impose preventive freezing measures.

-Significantly higher administrative and criminal penalties, with corporate fines reaching up to AED 100 million, alongside potential licence suspension or dissolution in cases of serious or repeated non-compliance.

-Entities subject to the AML/CFT regime are expected to review and upgrade their governance structures, internal controls, and compliance systems without delay.

Federal Decree-Law No. 10 of 2025: A Fundamental Shift in the UAE AML/CFT Framework

Federal Decree-Law No. 10 of 2025 represents the most comprehensive reform of the UAE’s AML/CFT framework to date. Effective from 14 October 2025, it repeals Federal Law No. 20 of 2018, following interim amendments introduced in 2024.

The new law does not merely consolidate existing obligations; it fundamentally recalibrates how compliance is assessed, enforced, and penalised. While the legislation is now in force, existing Executive Regulations, ministerial resolutions, and regulatory circulars remain applicable until formally replaced.

In this regard, Cabinet Resolution No. 10 of 2019 will be repealed by Cabinet Resolution No. 134 of 2025, which sets out the new Executive Regulations on combating money laundering, terrorist financing, and the financing of the proliferation of weapons, effective 14 December 2025.

During this transitional period, regulated entities must continue to comply with existing instruments while preparing their systems, policies, and controls for the enhanced obligations introduced under the new regime.

Scope and Regulatory Intent of the New AML Law

Through Federal Decree-Law No. 10 of 2025, the UAE has reinforced its commitment to maintaining a robust, internationally aligned financial crime framework. The law expands the scope of criminalised conduct, strengthens supervisory authority, and directly addresses risks arising from digital assets, cross-border transactions, and evolving financial technologies.

The introduction of Proliferation Financing as a standalone offence reflects alignment with international standards and underscores the UAE’s focus on addressing emerging global financial crime risks.

Any entity engaged in regulated financial or designated non-financial activities must now meet higher compliance standards, including enhanced due diligence, improved monitoring and reporting, and strengthened internal risk governance.

Practical Implications for Businesses

The new AML/CFT law materially increases regulatory expectations for boards, senior management, and compliance functions. Demonstrable compliance, effective risk assessment, and properly documented internal controls will be critical in mitigating enforcement exposure.

Failure to adapt to the new framework may result not only in substantial financial penalties but also in regulatory restrictions that directly impact business continuity.

At AT-LAW, we advise financial institutions, DNFBPs, virtual asset businesses, and corporate groups on navigating complex regulatory transitions. The implementation of Federal Decree-Law No. 10 of 2025 requires a structured, legally sound approach that aligns regulatory obligations with operational realities.

Early legal assessment, targeted gap analysis, and governance-focused compliance planning are essential to managing risk under the new AML/CFT framework.