Federal Decree by Law No. (10) of 2025 on Anti-Money Laundering and Combating the Financing of Terrorism and Proliferation Financing

The UAE issued Federal Decree by Law No. (10) of 2025 on Anti-Money Laundering and Combating the Financing of Terrorism and Proliferation Financing on 30 September 2025. The law was published in the Official Gazette and entered into force 14 days after publication, in accordance with Article (42).

This Decree by Law replaces the previous AML law and strengthens the UAE’s legal system for preventing, detecting, and penalising money laundering, terrorist financing, and proliferation financing, in line with international standards.

Purpose and Scope of the Law

The Decree by Law applies to all acts related to money laundering, financing of terrorism, and financing of the proliferation of weapons of mass destruction, whether committed by individuals or legal persons.

It governs financial institutions, designated non-financial businesses and professions (DNFBPs), virtual asset service providers, non-profit organisations, and any other persons or entities specified in the executive regulations. The law also applies to predicate offences committed inside or outside the UAE where the proceeds are laundered in the State.

Key Definitions

Article (1) sets out the key definitions used throughout the law. These include definitions of money laundering, financing of terrorism, proliferation financing, funds, predicate offence, beneficial owner, suspicious transactions, supervisory authorities, the Financial Intelligence Unit, and virtual asset service providers. These definitions determine how obligations, liabilities, and penalties are applied.

Money Laundering Offences

Under Article (2), money laundering is committed when a person knowingly converts, transfers, conceals, acquires, possesses, or uses funds derived from a predicate offence, or assists the offender to evade punishment. The offence applies even if the predicate offence was committed outside the UAE.

Money laundering is treated as an independent crime, and a conviction for the underlying offence is not required for prosecution.

Financing of Terrorism and Proliferation Financing

Article (3) criminalises the intentional provision, collection, or availability of funds with knowledge that they will be used to commit or support terrorist acts, terrorist organisations, or terrorist individuals. The offence also covers funding terrorist travel, training, or preparation.

The same article criminalises proliferation financing, which includes funding activities related to the manufacture, acquisition, possession, development, transport, or use of weapons of mass destruction and related materials.

Criminal Liability of Legal Persons

Under Article (4), legal persons are criminally liable if money laundering, terrorist financing, or proliferation financing offences are committed in their name or for their benefit. This liability does not prevent prosecution of individuals who participated in the offence.

Suspension, Freezing, and Seizure of Funds

Article (5) authorises the Head of the Financial Intelligence Unit to temporarily suspend suspicious transactions or freeze funds for specified periods where there is reasonable suspicion of money laundering, terrorist financing, or proliferation financing. These measures may be extended with approval from the Public Prosecution.

Under Article (6), the Public Prosecution or competent court may order the identification, seizure, freezing, management, or valuation of funds and criminal proceeds, as well as impose travel bans during investigations or trials.

Investigations and Information Powers

Articles (7) to (9) regulate investigative procedures, including the management of seized funds and the powers of competent authorities to request information from reporting entities. These provisions ensure access to financial and transactional information while protecting confidentiality.

Financial Intelligence Unit

Article (11) establishes the Financial Intelligence Unit (FIU) as the central authority responsible for receiving, analysing, and disseminating suspicious transaction reports. The FIU may exchange information with domestic and foreign counterparts and support law enforcement authorities in combating financial crimes.

National Coordination Committees

Under Article (12), a Supreme Committee for the Supervision of the National Strategy is established under the Presidential Court to oversee national policies related to AML, counter-terrorism financing, and proliferation financing.

Article (13) establishes the National Committee for Combating Money Laundering, Financing of Terrorism and Proliferation Financing, chaired by the Governor of the Central Bank. The committee coordinates between competent authorities and follows up on national and international obligations.

Supervision and Preventive Measures

Articles (16) to (22) assign supervisory responsibilities to relevant authorities over financial institutions, DNFBPs, virtual asset service providers, and non-profit organisations.

These provisions require entities to implement preventive measures, including customer due diligence, beneficial ownership identification, record-keeping, internal controls, risk assessments, and reporting of suspicious transactions.

Statistics and Confidentiality

Under Article (23), competent authorities must maintain statistics related to suspicious transaction reports, investigations, prosecutions, and seized funds to assess the effectiveness of AML measures.

Article (24) requires that all information related to suspicious transactions and investigations be treated as confidential and used only for lawful purposes.

Penalties and Sanctions

Articles (25) to (37) set out criminal penalties for violations of the law. Money laundering offences carry imprisonment and substantial fines, with enhanced penalties in aggravating circumstances.

Financing of terrorism may result in long-term imprisonment or life imprisonment, while proliferation financing offences carry severe custodial and financial penalties. Legal persons may face heavy fines, suspension of activities, or dissolution in serious cases.

The law also provides protection for reporting entities acting in good faith and confirms that crimes under this Decree by Law are not subject to limitation periods, as stated in Article (37).

Repeal and Final Provisions

Article (41) repeals Federal Decree by Law No. (20) of 2018 on Anti-Money Laundering and Combating the Financing of Terrorism, along with any provisions that conflict with the new law. Existing executive regulations and decisions remain applicable until replaced.

Article (42) confirms the law’s publication and entry into force.

Conclusion

Federal Decree by Law No. (10) of 2025 significantly strengthens the UAE’s legal regime against money laundering, financing of terrorism, and proliferation financing. The law introduces clear offences, strong investigative powers, strict compliance obligations, and severe penalties, reinforcing the UAE’s commitment to financial integrity and international cooperation.