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Cabinet Resolution Regarding the Executive Regulations of Federal Decree by Law Regarding Anti-Money Laundering, and Combating the Financing of Terrorism and Proliferation Financing

Analysis of Cabinet Resolution Regarding the Executive Regulations of Federal Decree by Law Regarding Anti-Money Laundering, and Combating the Financing of Terrorism and Proliferation Financing (Federal Decree-Law, ) — covering scope, key definitions, obligations, penalties, and interaction with ...

Legislation Details

  • Full Title: Cabinet Resolution Regarding the Executive Regulations of Federal Decree by Law Regarding Anti-Money Laundering, and Combating the Financing of Terrorism and Proliferation Financing
  • Law Type: Federal Decree-Law
  • Law Number: No. (134) of 2025
  • Issued Date: 29 Oct 2025
  • Effective Date: 14 Dec 2025
  • Official Gazette: No. 811
  • Sector: Security and Safety
  • Status: Active
  • Number of Articles: 173
  • Chapters/Parts: 9 Chapters
  • Amendments: 0

Summary

This Federal Decree-Law establishes the executive regulations for the UAE's anti-money laundering, counter-terrorism financing, and counter-proliferation financing framework. It defines the obligations and requirements for financial institutions, designated non-financial businesses and professions (DNFBPs), virtual asset service providers, and non-profit organizations operating in the UAE. The law also outlines the powers and responsibilities of the Financial Intelligence Unit, the National Committee, and the supervisory authorities responsible for enforcing compliance. (Cabinet Resolution Regarding the Executive Regulations of Federal Decree by Law Regarding Anti-Money Laundering, and Combating the Financing of Terrorism and Proliferation Financing, 2025) This legislation is critical for businesses and individuals in the UAE, as it establishes a comprehensive framework to prevent the misuse of the UAE's financial system for illicit purposes. Failure to comply with the law's obligations can result in significant penalties, including imprisonment and heavy fines. The law's impact is far-reaching, as it applies to a wide range of entities operating in the UAE and mandates robust customer due diligence, reporting, and record-keeping requirements. (Cabinet Resolution Regarding the Executive Regulations of Federal Decree by Law Regarding Anti-Money Laundering, and Combating the Financing of Terrorism and Proliferation Financing, 2025)

What is the scope and purpose of this law?

The scope of this law is to establish the executive regulations for Federal Decree-Law No. (10) of 2025 Regarding Anti-Money Laundering, and Combating the Financing of Terrorism and Proliferation Financing. The law applies to financial institutions, designated non-financial businesses and professions (DNFBPs), virtual asset service providers, and non-profit organizations operating in the UAE. (Cabinet Resolution Regarding the Executive Regulations of Federal Decree by Law Regarding Anti-Money Laundering, and Combating the Financing of Terrorism and Proliferation Financing, 2025, Art. 1) The purpose of this law is to provide a comprehensive regulatory framework to prevent the misuse of the UAE's financial system for money laundering, terrorism financing, and proliferation financing activities. It outlines the obligations and requirements for relevant entities to implement robust customer due diligence, reporting, and record-keeping measures to combat these illicit activities. (Cabinet Resolution Regarding the Executive Regulations of Federal Decree by Law Regarding Anti-Money Laundering, and Combating the Financing of Terrorism and Proliferation Financing, 2025, Preamble)

What are the key definitions under this law?

The law provides the following key definitions:

  • Companies: Companies, regardless of their type or activity, that are subject to the provisions of the legislation in force in the State. (Cabinet Resolution Regarding the Executive Regulations of Federal Decree by Law Regarding Anti-Money Laundering, and Combating the Financing of Terrorism and Proliferation Financing, 2025, Art. 1)
  • Senior Management: The person or persons vested with authority to take strategic and executive decisions materially affecting risk management, compliance policies, and operational governance. (Cabinet Resolution Regarding the Executive Regulations of Federal Decree by Law Regarding Anti-Money Laundering, and Combating the Financing of Terrorism and Proliferation Financing, 2025, Art. 1)
  • Financial Institutions: Any person engaging in one or more financial activities or operations for the benefit of, or on behalf of, a Customer. (Cabinet Resolution Regarding the Executive Regulations of Federal Decree by Law Regarding Anti-Money Laundering, and Combating the Financing of Terrorism and Proliferation Financing, 2025, Art. 1)
  • Designated Non-Financial Businesses and Professions (DNFBPs): Any person engaging in one or more commercial or professional activities or businesses for the benefit of, or on behalf of, a Customer. (Cabinet Resolution Regarding the Executive Regulations of Federal Decree by Law Regarding Anti-Money Laundering, and Combating the Financing of Terrorism and Proliferation Financing, 2025, Art. 1)
  • Virtual Asset Service Providers: Any person who, as a commercial activity, conducts one or more Virtual Asset activities or related operations for the benefit of, or on behalf of, another natural or legal person. (Cabinet Resolution Regarding the Executive Regulations of Federal Decree by Law Regarding Anti-Money Laundering, and Combating the Financing of Terrorism and Proliferation Financing, 2025, Art. 1)
  • Beneficial Owner: The natural person who owns or exercises ultimate effective control over the Customer, or the natural person on whose behalf Transactions are conducted. (Cabinet Resolution Regarding the Executive Regulations of Federal Decree by Law Regarding Anti-Money Laundering, and Combating the Financing of Terrorism and Proliferation Financing, 2025, Art. 1)

What are the main obligations and requirements?

The law imposes several key obligations on financial institutions, DNFBPs, and virtual asset service providers operating in the UAE: 1. Implement risk identification and mitigation measures, including customer due diligence and beneficial owner identification procedures. (Cabinet Resolution Regarding the Executive Regulations of Federal Decree by Law Regarding Anti-Money Laundering, and Combating the Financing of Terrorism and Proliferation Financing, 2025, Arts. 5-15) 2. Establish internal supervision and compliance programs, including the appointment of a compliance officer. (Cabinet Resolution Regarding the Executive Regulations of Federal Decree by Law Regarding Anti-Money Laundering, and Combating the Financing of Terrorism and Proliferation Financing, 2025, Arts. 21-22) 3. Report suspicious transactions to the Financial Intelligence Unit. (Cabinet Resolution Regarding the Executive Regulations of Federal Decree by Law Regarding Anti-Money Laundering, and Combating the Financing of Terrorism and Proliferation Financing, 2025, Arts. 17-19) 4. Comply with specific requirements for correspondent banking relationships, money or value transfer services, and wire transfers. (Cabinet Resolution Regarding the Executive Regulations of Federal Decree by Law Regarding Anti-Money Laundering, and Combating the Financing of Terrorism and Proliferation Financing, 2025, Arts. 26-31) 5. Maintain comprehensive records of customer information and transactions for at least 5 years. (Cabinet Resolution Regarding the Executive Regulations of Federal Decree by Law Regarding Anti-Money Laundering, and Combating the Financing of Terrorism and Proliferation Financing, 2025, Art. 25)

What licensing, registration, or approval requirements exist?

The law does not specify any licensing, registration, or approval requirements for financial institutions, DNFBPs, or virtual asset service providers. The legislation is focused on outlining the obligations and requirements for these entities rather than the process for obtaining licenses or approvals.

What rights and protections does this law provide?

The law does not explicitly outline any specific rights or protections granted to individuals, businesses, or other parties. The focus of the legislation is on establishing the obligations and requirements for relevant entities to combat money laundering, terrorism financing, and proliferation financing activities.

Which authorities or bodies are responsible for enforcement?

The law establishes the following key authorities and bodies responsible for enforcement: 1. The Financial Intelligence Unit: Responsible for receiving, analyzing, and disseminating suspicious transaction reports, as well as cooperating with domestic and international authorities. (Cabinet Resolution Regarding the Executive Regulations of Federal Decree by Law Regarding Anti-Money Laundering, and Combating the Financing of Terrorism and Proliferation Financing, 2025, Arts. 44-47) 2. The National Committee: Responsible for coordinating national efforts to combat money laundering, terrorism financing, and proliferation financing. (Cabinet Resolution Regarding the Executive Regulations of Federal Decree by Law Regarding Anti-Money Laundering, and Combating the Financing of Terrorism and Proliferation Financing, 2025, Art. 48) 3. The Supervisory Authority: Responsible for supervising financial institutions, DNFBPs, and virtual asset service providers for compliance with the law's requirements. (Cabinet Resolution Regarding the Executive Regulations of Federal Decree by Law Regarding Anti-Money Laundering, and Combating the Financing of Terrorism and Proliferation Financing, 2025, Arts. 49-50)

What are the penalties for non-compliance?

The law does not specify any penalties for non-compliance. The legislation is focused on outlining the obligations and requirements for relevant entities rather than detailing the penalties for failure to comply.

What fees, charges, or financial provisions are specified?

The law does not mention any fees, charges, or financial provisions.

What exemptions or exceptions apply?

The law does not provide any exemptions or exceptions from its scope or requirements.

How are disputes resolved under this law?

The law does not specify any dispute resolution mechanisms or procedures.

What are the key deadlines and time limits?

The law does not establish any specific deadlines or time limits for compliance with its requirements.

How does this law interact with other UAE legislation?

The law references the following related legislation: - Federal Law No. (1) of 1972 Regarding the Competences of the Ministries and the Powers of Ministers, as amended. - Federal Decree by Law No. (10) of 2025 Regarding Anti-Money Laundering, and Combating the Financing of Terrorism and Proliferation Financing. - Cabinet Resolution No. (10) of 2019 Regarding the Executive Regulations of Federal Decree by Law No. (20) of 2018 Regarding Anti-Money Laundering, and Combating the Financing of Terrorism and Illegal Organizations, as amended. (Cabinet Resolution Regarding the Executive Regulations of Federal Decree by Law Regarding Anti-Money Laundering, and Combating the Financing of Terrorism and Proliferation Financing, 2025, Preamble)

When did this law come into effect?

This Cabinet Resolution came into effect on 14 December 2025, as stated in the Effective Date. (Cabinet Resolution Regarding the Executive Regulations of Federal Decree by Law Regarding Anti-Money Laundering, and Combating the Financing of Terrorism and Proliferation Financing, 2025)

Source Documents

This article analyses Cabinet Resolution Regarding the Executive Regulations of Federal Decree by Law Regarding Anti-Money Laundering, and Combating the Financing of Terrorism and Proliferation Financing for legal research and educational purposes. For the purpose of interpretation and application, reference must be made to the original Arabic text. In case of conflict, the Arabic text prevails. This does not constitute legal advice.

Written by Sushant Shukla

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