The UAE Enacts a New AML Law: What Are the Key Changes and What Does This Mean for Your Business?

David Berman, Naina Pagarani
White & Case LLP
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The UAE has enacted Federal Law No. 10 of 2025, Concerning Combating Money Laundering, Terrorism Financing, and the Financing of Proliferation, (the "New AML Law"), which repeals and replaces Federal Law No. 20 of 2018 (as amended) (the "Previous AML Law"). This change follows a year after amendments were made to the Previous AML Law through Federal Decree Law No. 7 of 2024.

The New AML Law introduces some significant amendments and a series of refinements which are designed to further strengthen the UAE's existing anti-money laundering ("AML") and counter-terrorist financing ("CTF") regime. The New AML Law now also includes a framework for combatting proliferation financing ("CPF"), to further align it with the Financial Action Task Force's standards.

The New AML Law came into effect on 14 October 2025, following its publication in the UAE's Official Gazette on 30 September 2025.

Key changes at a glance

  • The UAE's AML/CTF/CPF regime has been enhanced, with new offences and penalties (including for proliferation financing), broader coverage of existing offences, and lower legal thresholds to establish the principal money laundering, terrorist financing and (now) proliferation financing offences (together, the "Principal Offences").
  • There are increased penalties for legal entities. Managers of legal entities can now also be subject to personal criminal liability in certain circumstances.
  • Violations for illicit activities through the use of digital systems and virtual assets are now expressly captured under the framework.
  • The supervisory and enforcement toolkit available to UAE supervision and law enforcement authorities has been expanded, including with respect to freezing potentially illicit assets, and promoting inter-agency cooperation, both within the UAE and internationally.

Comparison table: key differences between the New AML Law and the Previous AML Law

Topic Position under the New AML Law Position under the Previous AML Law
New offences and expanded coverage of existing offences

Proliferation financing offences have been expressly included in the New AML Law.

The New AML Law also expressly addresses the use of digital systems, virtual assets and encryption technologies as methods of committing the Principal Offences.

The Previous AML Law was limited to money laundering and terrorist financing offences. It did not include proliferation financing offences.

The Previous AML Law did not expressly capture the use of digital systems, virtual assets and encryption technologies as methods of committing money laundering and terrorist financing offences.
Broadened definition of the predicate offence for the offence of money laundering The definition of a 'predicate offence' for the purpose of establishing a money laundering offence now also specifically includes the crimes of terrorist financing, arms proliferation financing and indirect and direct tax evasion. Under the Previous AML Law, a 'predicate offence' was any act constituting a felony or misdemeanor (committed within or outside of the UAE).
Lowered legal threshold for establishing the Principal Offences

The legal threshold for establishing the Principal Offences has been lowered.

Under the New AML Law, knowledge that funds were illicit can be inferred from the factual and objective circumstances (an objective test).

This means that liability can arise where a person either actually knew or it would have been reasonable for them to have known about the illicit nature of the funds in question.

 Under the Previous AML Law, it was necessary to prove that a person had actual knowledge that the funds were illicit, in order to establish liability for a money laundering or terrorist financing offence (a subjective test). There was no objective test included in the legislation.
Increased penalties for the Principal Offences and inclusion of personal criminal liability for managers

Under the New AML Law, penalties for the Principal Offences have significantly increased, as follows:

  • Legal entities can be subject to a fine of between AED 5 million and AED 100 million or a sum equivalent to the value of the criminal property (whichever is greater), if their representatives, managers or agents commit any of the Principal Offences on behalf of the entity or in the entity's name.
  • Regulated entities can be subject to a fine of between AED 200,000 and AED 10 million for failure to have the requisite licensing or authorisations to conduct their operations.
  • Courts may order the dissolution of a legal entity or the closure of its headquarters if it is convicted of a Principal Offence.

Managers of legal entities can now also be subject to personal criminal liability and risk exposure to a fine or imprisonment if they have actual knowledge of a Principal Offence or if a Principal Offence occurred as a result of a breach of their employment duties.

Under the Previous AML Law, penalties for money laundering and terrorist financing offences were as follows:

  • Legal entities could be subject to a fine of between AED 500,000 and AED 50 million, if their representatives, managers or agents committed the offences of money laundering, terrorist financing or financing of illegal organisations on behalf of the entity or in the entity's name.
  • Regulated entities could be subject to a fine of between AED 200,000 and AED 5 million for failure to have the requisite licensing or authorisations to conduct their operations.
  • Courts could only order the dissolution of a legal entity or the closure of its headquarters if it was convicted of an offence of terrorist financing or financing illegal organisations (but not for the offence of money laundering).

There was no specific criminal liability placed upon managers of legal entities for actual knowledge of a relevant offence or if the relevant offence occurred as a result of a breach of their duties.
Introduction of a new offence targeting misuse of accounts held within financial institutions or virtual asset service providers ("VASPs") Under the New AML Law, it is an offence for a person to enable a third party to benefit from use of an account within financial institutions or VASPs if that person has actual knowledge or there is sufficient evidence to suggest that the third party intends to misuse the account. A person that commits such an offence can be subject to a fine or imprisonment. There was no similar offence under the Previous AML Law.
Expansion of the FIU's enforcement powers

The FIU has been granted the power to issue the following orders:

  • A seizure order, to suspend transactions suspected to be linked to financial crime for up to 10 working days, without providing prior notice.
  • A freezing order, to freeze funds suspected to be linked to financial crime, held by financial institutions, designated non-financial businesses and professions ("DNFBPs") or VASPs, for a period of 30 days (such period is extendable).

Under a freezing order, the assets remain under the control of the entity that is subject of the order, for the duration of the order.

Under the Previous AML Law, only:

  • the Governor of the UAE Central Bank and the Public Prosecutor could exercise the power to seize funds, suspected to be linked to financial crime.
  • the Governor of the UAE Central Bank could exercise the power to freeze funds suspected to be linked to a financial crime, held by financial institutions up to a period of seven days.
Introduction of enforcement powers to foster inter-agency cooperation within the UAE

The following changes have been introduced to encourage further cooperation between UAE law enforcement authorities:

  • The Public Prosecution has the ability to consider the FIU's input, including its financial analysis on applicable data.
  • Other law enforcement agencies may access and share information to identify and track criminal property. The applicable law enforcement agencies also have the right to receive and follow-up on the FIU's reports.
 Cooperation between law enforcement bodies under the Previous AML Law was focused on the FIU cooperating with its international counterpart agencies.
Introduction of the UAE courts' powers to implement foreign orders The New AML Law broadens the UAE courts' powers, permitting them to implement foreign orders for 'provisional measures' or confiscate criminal property (or sums of an equivalent value) without the need to carry out a local, UAE-based money laundering investigation. There was no similar power conferred on the UAE courts under the Previous AML Law.

What does the introduction of the New AML Law mean for your business?

The UAE's continuing and rapid development of its AML/CTF/CPF regime reflects its ongoing commitment to demonstrating to local, regional, and global financial markets that combating financial crime remains a top priority for the country as a leading global financial and economic centre, and will continue to do so.

As regards enforcement risk, even before the introduction of the New AML Law, there had been a significant increase in AML/CTF enforcement activity in the UAE. The introduction of the New AML Law may signal yet even more active enforcement to come, particularly in light of the increases to penalties for existing offences, the introduction of new offences, which capture a wider range of conduct and individuals, and the additional powers conferred on the FIU and other law enforcement authorities, which are contained in the New AML Law.

We also expect to see greater inter-agency cooperation within the UAE. On 7 October 2025, the 'UAE National Strategy for AML/CFT/CPF Retreat' took place in Dubai involving over 50 senior officials representing federal and local authorities. At this meeting, there was a review of the UAE's 'National Strategy' for 2024 – 2027 and a look ahead to the priorities for the next cycle from 2027 to 2031. One of the outcomes of this retreat was that participants committed to accelerating delivery of the 'National Action Plan' through agile strategy cycles, enhanced inter-agency collaboration, and robust data-sharing mechanisms.

In light of this rapidly evolving regulatory environment, businesses operating in or considering entry into the UAE should:

  • pay close and ongoing attention to legislative and regulatory changes in this area; and
  • carefully review their compliance arrangements and allocate sufficient resources to ensure they meet all applicable legal requirements and regulatory expectations, including rolling out adequate training to senior managers and other relevant personnel.

New executive regulations to accompany the New AML Law are expected to be published and enter into force shortly. Until then, the existing executive regulations (Cabinet Decision No.10 of 2019) remain in force.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations. Attorney Advertising.

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