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UAE

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

Analysis 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 other UAE legislation.

Legislation Details

  • Full Title: Federal Decree by Law Regarding Anti-Money Laundering, and Combating the Financing of Terrorism and Proliferation Financing
  • Law Type: Federal Decree-Law
  • Law Number: [10] of 2025
  • Issued Date: 30 Sep 2025
  • Effective Date: 14 Oct 2025
  • Official Gazette: No. 808
  • Sector: Security and Safety
  • Status: Active
  • Number of Articles: 97
  • Chapters/Parts: 13
  • Amendments: 0

Summary

This Federal Decree-Law regulates anti-money laundering, combating the financing of terrorism, and combating the financing of proliferation in the United Arab Emirates. It defines key terms, establishes crimes and penalties, sets out investigative procedures, and creates various authorities and committees to oversee implementation and enforcement. The law is crucial for businesses and individuals in the UAE, as it imposes strict compliance requirements and significant penalties for non-compliance, helping to safeguard the UAE's financial system and national security. (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 Federal Decree-Law is to regulate anti-money laundering, combating the financing of terrorism, and combating the financing of proliferation within the United Arab Emirates. Its purpose is to prevent and combat these crimes, protect the UAE's financial system, and ensure national security. The law applies to all natural and legal persons in the UAE, as well as any activities or transactions conducted within or outside the UAE that are subject to the jurisdiction of the UAE authorities. (Federal Decree by Law Regarding Anti-Money Laundering, and Combating the Financing of Terrorism and Proliferation Financing, 2025, Art. 1)

What are the key definitions under this law?

The law provides the following key definitions:

  • The State: The United Arab Emirates
  • Money Laundering: Any of the acts defined in Article 2(1) of the law, including through digital systems, virtual assets, or cryptographic technologies
  • Terrorist Act: Any unlawful act intended to cause death, serious bodily injury, or substantial property/environmental damage, with the purpose of instilling terror or influencing authorities
  • Terrorist: A natural person who commits, attempts, participates in, organizes, or incites a terrorist act
  • Financing of Terrorism: Any of the acts defined in Article 3(1) of the law
  • Proliferation: The illicit and unauthorized trade in materials, systems, equipment, etc. contributing to weapons of mass destruction
  • Funds: Assets or properties of any type or form, including digital and cryptographic forms
  • Virtual Assets: Digital representations of value that may be traded or transferred for payment or investment purposes
  • Financial Institutions: Persons engaged in financial activities or operations
  • Designated Non-Financial Businesses and Professions (DNFBPs): Persons engaged in certain commercial or professional activities
  • Beneficial Owner: The natural person who owns or controls the customer or on whose behalf transactions are conducted

(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: 1. Financial institutions, DNFBPs, and virtual asset service providers must implement customer due diligence measures, monitor transactions, and report suspicious transactions to the Financial Intelligence Unit. (Federal Decree by Law Regarding Anti-Money Laundering, and Combating the Financing of Terrorism and Proliferation Financing, 2025, Art. 18-20) 2. Persons must disclose information about funds or assets related to money laundering, terrorism financing, or proliferation financing when requested by the authorities. (Federal Decree by Law Regarding Anti-Money Laundering, and Combating the Financing of Terrorism and Proliferation Financing, 2025, Art. 10) 3. The Financial Intelligence Unit, supervisory authorities, and law enforcement authorities must cooperate and exchange information to combat these crimes. (Federal Decree by Law Regarding Anti-Money Laundering, and Combating the Financing of Terrorism and Proliferation Financing, 2025, Art. 11-17)

What licensing, registration, or approval requirements exist?

The law does not specify any licensing, registration, or approval requirements. It focuses on the obligations of financial institutions, DNFBPs, and virtual asset service providers, but does not mention any formal licensing or registration processes.

What rights and protections does this law provide?

The law does not explicitly outline any specific rights or protections granted to individuals or businesses. It is focused on establishing the legal framework to combat money laundering, terrorism financing, and proliferation financing, and the obligations and penalties associated with these crimes.

Which authorities or bodies are responsible for enforcement?

The law establishes several key authorities and bodies responsible for enforcement and implementation: - The Supreme Committee for the Supervision of the National Strategy for Anti-Money Laundering, Combating the Financing of Terrorism and Proliferation Financing - The National Committee for Anti-Money Laundering, Combating the Financing of Terrorism, and Proliferation Financing - The General Secretariat of the National Committee - The Financial Intelligence Unit - The Supervisory Authorities (federal and local authorities overseeing financial institutions, DNFBPs, virtual asset service providers, and NPOs) - The Law Enforcement Authorities (federal and local authorities combating and investigating these crimes) - The Executive Office for Control and Non-Proliferation (implements targeted financial sanctions) (Federal Decree by Law Regarding Anti-Money Laundering, and Combating the Financing of Terrorism and Proliferation Financing, 2025, Art. 1, 11-17)

What are the penalties for non-compliance?

The law specifies the following penalties for non-compliance: - Imprisonment of 3-15 years and a fine of AED 1-5 million for money laundering offenses (Federal Decree by Law Regarding Anti-Money Laundering, and Combating the Financing of Terrorism and Proliferation Financing, 2025, Art. 25) - Imprisonment of 5-15 years and a fine of AED 2-10 million for terrorism financing offenses (Federal Decree by Law Regarding Anti-Money Laundering, and Combating the Financing of Terrorism and Proliferation Financing, 2025, Art. 26) - Imprisonment of 5-15 years and a fine of AED 2-10 million for proliferation financing offenses (Federal Decree by Law Regarding Anti-Money Laundering, and Combating the Financing of Terrorism and Proliferation Financing, 2025, Art. 27) - Administrative penalties such as fines, suspension, or revocation of licenses for financial institutions, DNFBPs, and virtual asset service providers (Federal Decree by Law Regarding Anti-Money Laundering, and Combating the Financing of Terrorism and Proliferation Financing, 2025, Art. 39)

What fees, charges, or financial provisions are specified?

The law does not specify any fees, charges, or other financial provisions. It is focused on establishing the legal framework and penalties for non-compliance, rather than outlining any financial requirements.

What exemptions or exceptions apply?

The law does not provide any explicit exemptions or exceptions. It applies broadly to all natural and legal persons in the UAE, as well as any activities or transactions conducted within or outside the UAE that are subject to the jurisdiction of the UAE authorities.

How are disputes resolved under this law?

The law does not specify any dispute resolution mechanisms. It is focused on establishing the legal framework, authorities, and penalties for non-compliance, rather than outlining procedures for resolving disputes.

What are the key deadlines and time limits?

The law does not mention any specific deadlines or time limits. It is focused on the general obligations and requirements, rather than prescribing any timelines for compliance or reporting.

How does this law interact with other UAE legislation?

The law references and builds upon several other UAE federal laws, including: - Federal Law No. (1) of 1972 Regarding the Competences of the Ministries and the Powers of Ministers - Federal Law No. (39) of 2006 Regarding International Judicial Cooperation in Criminal Matters - Federal Law No. (7) of 2014 Regarding Combating Terrorist Crimes - Federal Decree by Law No. (20) of 2018 Regarding Anti-Money Laundering, the Financing of Terrorism, and the Financing of Illegal Organizations - Federal Decree by Law No. (30) of 2021 Regarding Combating Narcotics and Psychotropic Substances - Federal Decree by Law No. (31) of 2021 Promulgating the Crimes and Penalties Law - Federal Decree by Law No. (34) of 2021 Regarding Countering Rumors and Cybercrimes - Federal Decree by Law No. (38) of 2022 Promulgating the Criminal Procedure Law (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 Federal Decree-Law came into effect on 14 October 2025, as specified in the Effective Date. It was issued on 30 September 2025 and published in Official Gazette No. 808. (Federal Decree by Law Regarding Anti-Money Laundering, and Combating the Financing of Terrorism and Proliferation Financing, 2025)

Source Documents

This article analyses 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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