The United Arab Emirates has entered a new phase of financial crime enforcement. With the entry into force of Federal Decree‑Law No. 10 of 2025 Regarding Anti‑Money Laundering and Combating the Financing of Terrorism and Proliferation Financing (the “2025 Anti‑Money Laundering Law”), the State has modernised and tightened its criminal framework for money laundering at a level that directly affects every business, financial institution and professional intermediary operating in or through the United Arab Emirates.
The law repeals and replaces Federal Decree Law No. 20 of 2018 on Anti-Money Laundering, Combating the Financing of Terrorism and Financing of Illegal Organisations, which was the previous primary federal anti-money laundering framework before its repeal on the entry into force of Federal Decree Law No. 10 of 2025 on Anti-Money Laundering and Combating the Financing of Terrorism and Proliferation Financing on 14 October 2025. The new law, while preserving the core policy objective: to protect the integrity of the United Arab Emirates financial system, maintain international confidence and keep the country aligned with the recommendations of the Financial Action Task Force. According to the official United Arab Emirates legislation portal, Federal Decree‑Law No. 10 of 2025 was issued on 30 September 2025, published in Official Gazette No. 808, entered into force on 14 October 2025 and is currently in active effect across the State.
For business owners, compliance officers and legal practitioners, understanding the criminalisation mechanics under the new United Arab Emirates anti‑money laundering law of 2025 is now a strategic requirement. The law recalibrates the notion of criminal intent, reinforces the autonomy of money laundering offences, expands the concept of criminal property, and substantially raises United Arab Emirates money laundering penalties for both individuals and legal persons.
Legislative landscape and relationship with previous anti‑money laundering law
The current federal framework on money laundering offences in the United Arab Emirates is anchored in Federal Decree‑Law No. 10 of 2025 Regarding Anti‑Money Laundering and Combating the Financing of Terrorism and Proliferation Financing.
This statute:
- Repeals and replaces Federal Decree‑Law No. 20 of 2018 on Anti‑Money Laundering and Combating the Financing of Terrorism and Illegal Organisations, which served as the principal anti‑money laundering law until October 2025.
- The 2025 Anti-Money Laundering Law is supported by its new executive regulations issued by Cabinet Resolution No. 134 of 2025 Concerning the Executive Regulations of Federal Decree Law No. 10 of 2025 on Anti-Money Laundering and Combating the Financing of Terrorism and Proliferation Financing, which repeals and replaces prior executive regulations under the 2018 framework. These implementing regulations remain the primary source of detailed compliance obligations until they are amended or replaced.
- Integrates proliferation financing as a core component of the anti‑money laundering framework, and codifies targeted financial sanctions at primary legislation level, thereby aligning United Arab Emirates law with recent international standards and supporting the country’s removal from the Financial Action Task Force “grey list” and the European Union high‑risk list.
From a criminal law perspective, the reference Penal Code remains Federal Decree‑Law No. 31 of 2021 on Issuing the Crimes and Penalties Law, including its provisions on plurality of crimes and penalties, in particular Articles 88 and 89, which continue to govern concurrence of offences except where specific legislation such as the 2025 Anti‑Money Laundering Law provides otherwise. Federal Decree‑Law No. 31 of 2021 remains in force and constitutes the general criminal law of the State.
For practitioners, any analysis of money laundering offences in the United Arab Emirates now requires a combined reading of:
- Federal Decree‑Law No. 10 of 2025 (substantive anti‑money laundering, counter‑terrorism financing and proliferation financing offences and penalties).
- Federal Decree‑Law No. 31 of 2021 (general criminal law, rules on criminal intent, concurrence of offences, corporate criminal liability framework and limitation periods).
- The still‑applicable implementing regulations and regulatory rules issued by the Central Bank of the United Arab Emirates, the Ministry of Economy, the Securities and Commodities Authority and the financial free zone regulators for supervisory and administrative aspects.
The 2025 Anti‑Money Laundering Law does not merely update penalties. It reshapes the underlying criminalisation architecture, particularly in relation to criminal intent standards under United Arab Emirates anti‑money laundering law and the evidentiary burden on prosecutors.
Recalibrated concept of knowledge and criminal intent
Money laundering remains an intentional offence under the United Arab Emirates anti‑money laundering law of 2025. However, Federal Decree‑Law No. 10 of 2025 materially lowers the evidentiary threshold for establishing the mental element of the crime.
Under Article 2 of the new law, any person commits the crime of money laundering if that person:
- Knows that all or part of the funds are proceeds of a predicate crime, or
- Has sufficient evidence or circumstantial evidence that supports such knowledge,
and then intentionally engages in specified acts of conversion, transfer, concealment, disguise, acquisition, possession or use of such funds.
This formulation has several important legal consequences:
- From actual knowledge to knowledge supported by circumstantial evidence
Under the 2018 framework, judicial practice focused on proof of actual knowledge of the illicit origin of the proceeds. The 2025 Anti‑Money Laundering Law expressly allows the court to infer knowledge from “sufficient evidence or circumstantial evidence”, enabling reliance on objective indicators such as transaction patterns, use of complex corporate structures, or implausible explanations for the source of funds. - No need to identify the precise predicate offence
The 2025 framework confirms that a conviction for money laundering does not depend on proving the exact category or type of predicate crime from which the proceeds arose, provided it is established that the funds originate from criminal activity. This reflects the autonomy of the money laundering offence from the underlying crime. - Autonomy from prior conviction for the predicate crime
Under Federal Decree Law No. 10 of 2025 on Anti-Money Laundering and Combating the Financing of Terrorism and Proliferation Financing, a prosecution for money laundering does not require a prior conviction for the predicate offence as a precondition for establishing the illicit nature of funds, and the legislative scheme expressly accommodates the inference of knowledge from objective and circumstantial evidence. This is consistent with the principle that money laundering protects distinct legal interests beyond those addressed by the predicate offence.
In practical terms, the criminal intent standard under United Arab Emirates anti‑money laundering law now focuses on what a reasonable person in the accused’s position ought to have appreciated, based on the available indicators and the person’s professional role and responsibilities.
Examples of circumstances that may support a finding of knowledge or deemed knowledge include:
- Use of complex, multi‑layered ownership structures without commercial justification.
- Rapid movement of funds through multiple accounts or jurisdictions inconsistent with declared business activities.
- Involvement of jurisdictions with limited transparency or higher risk classifications when this is not justified by the nature of the transaction.
- Persistent failure to obtain or retain basic documentation on the lawful source of funds or wealth, particularly where this is expected in the relevant sector.
For business owners and compliance officers, this shift imposes a higher expectation of vigilance. Wilful blindness or reckless disregard for clear risk indicators is now more readily convertible into criminal liability under the explicit wording of the law and the interpretive approach that it adopts.
Independence of money laundering offences from concurrence rules
Under the general rule of the United Arab Emirates Penal Code, where several offences are committed in execution of a single criminal purpose, the most severe penalty usually applies, reflecting the doctrine of concurrence of offences as set out in Articles 88 and 89 of Federal Decree‑Law No. 31 of 2021.
The 2025 Anti‑Money Laundering Law, however, safeguards the independence of money laundering offences from these concurrence provisions. Professional commentary and the structure of Federal Decree‑Law No. 10 of 2025 confirm that the legislator has intentionally preserved money laundering as a separate, stand‑alone crime, even when it is closely connected with the predicate crime or arises as part of the same criminal enterprise.
The implications are significant:
- Cumulative application of penalties
Where the same facts amount both to a predicate offence (for example, embezzlement, bribery, tax evasion or fraud) and to money laundering, the penalties for each offence may be applied cumulatively rather than being absorbed into a single, more serious penalty. This includes both custodial sentences and fines, as well as ancillary measures such as confiscation. - Separate legal interests protected
The criminalisation framework recognises that money laundering harms not only the immediate victim of the predicate crime, but also the integrity of the financial system and the reputation of the State. Treating the offences separately justifies additional punishment aimed at the use of the financial system to disguise criminal proceeds and undermine transparency. - Strategic enforcement leverage
Prosecutors may pursue money laundering charges even where evidentiary challenges exist for the predicate offence, thereby maintaining pressure on offenders and supporting asset‑recovery efforts. This has become more feasible given the reliance permitted on circumstantial evidence and the autonomy of the offence.
For legal practitioners, the conclusion is clear: in case assessments, settlement negotiations and risk analyses, it is no longer sufficient to consider only the base offence. Potential exposure to a parallel money laundering charge, with distinct United Arab Emirates money laundering penalties, must be factored into every strategic decision.
Offence structure, criminal property and penalty ranges
Federal Decree‑Law No. 10 of 2025 retains the basic structure of the money laundering offence but introduces critical innovations around the concept of criminal property and the calibration of penalties for both simple and aggravated forms of the offence.
Introduction and scope of criminal property
The new law defines “criminal property” in Article 1, significantly broadening the concept beyond mere “proceeds” of crime.
Criminal property now includes, among other categories:
- Proceeds derived from money laundering offences or any predicate crimes.
- Assets used or intended to be used in any manner in the commission of money laundering or predicate offences.
- Funds that form the subject matter of money laundering, terrorism financing or proliferation financing transactions.
- Funds used, allocated, or intended for the financing of terrorism, terrorist acts, terrorist organisations or proliferation financing.
- Proceeds derived from the commission of terrorism financing, terrorist acts, terrorist organisation crimes or proliferation financing offences.
This expanded notion is central to the new penalty regime, as the value of criminal property becomes a reference point, and in many cases the upper limit, for fines and confiscation.
Simple form of the money laundering offence
In what may be described as the standard or simple form of the offence, the new law provides that any person who commits money laundering shall be punished with:
- Imprisonment for a period not less than 1 year and not more than 10 years; and
- A fine of not less than 100,000 dirhams and not more than 5,000,000 dirhams or the equivalent value of the criminal property, whichever is greater.
Key features of this framework include:
- The introduction of a mandatory minimum custodial sentence of 1 year, thereby clarifying and hardening the lower bound of imprisonment compared with the 2018 regime.
- The requirement that the court impose both imprisonment and a fine in the ordinary case of conviction, significantly reducing judicial discretion to impose only one type of penalty and reinforcing deterrence.
- The link of the maximum fine to the value of criminal property. Where the value of the assets involved exceeds 5,000,000 dirhams, the fine can be increased to match or exceed that value. For high‑value laundering schemes, this dramatically raises financial exposure and aligns the sanction with the scale of the illicit activity.
Aggravated form of the money laundering offence
Under the 2025 Anti‑Money Laundering Law, certain aggravating circumstances elevate the offence to a more serious category, subject to temporary imprisonment and higher fines.
Aggravating factors include situations where:
- The offender abuses or exploits the authority or influence of his or her position, public office or professional activity.
- The offence is committed through a non‑profit organisation or within an organised criminal group.
- The predicate offence involves specified serious crimes, such as offences against public funds, bribery, embezzlement or certain national security offences.
- The offender is a recidivist or has previously been convicted of money laundering or related offences.
In such cases, the penalties are elevated as follows:
- Temporary imprisonment, which under the Crimes and Penalties Law may extend to substantially longer terms than basic imprisonment; and
- A fine of not less than 1,000,000 dirhams and not more than 10,000,000 dirhams or the equivalent of double the value of the criminal property, whichever is greater.
This structure ensures that in major or repeated money laundering schemes, the financial sanction is closely correlated to the scale of illicit funds involved and the degree of culpability.
Liability and penalties for legal persons
The law maintains and strengthens the liability of legal persons, such as companies, foundations and other entities, for money laundering offences committed in their name or for their benefit.
Where a legal person is convicted of a money laundering offence under Federal Decree Law No. 10 of 2025 on Anti-Money Laundering and Combating the Financing of Terrorism and Proliferation Financing, the applicable penalty includes a fine of not less than five million United Arab Emirates dirhams and not more than one hundred million United Arab Emirates dirhams, or the value of the criminal property, whichever is greater, and may include additional sanctions such as dissolution of the legal person.
For corporate clients, these United Arab Emirates money laundering penalties are transformational. A single violation can realistically threaten the viability of a business, not only through direct fines but also via the reputational and operational impact of dissolution or licence withdrawal by the relevant regulator.
Judicial discretion to mitigate or exempt from penalty
The new law preserves the possibility for the court to reduce or exempt an offender from punishment where that offender provides substantial assistance to the authorities.
Commentary on the law and comparative reading with Federal Decree‑Law No. 20 of 2018 indicate that mitigation may apply where the offender:
- Reports the offence before it is discovered by the authorities; or
- Provides information that leads to the identification or arrest of other perpetrators; or
- Assists in the tracing, freezing or confiscation of criminal property.
This encourages early cooperation and can form the basis of a negotiation strategy in complex corporate investigations, subject always to careful, case‑specific legal advice and consideration of exposure in multiple jurisdictions.
Confiscation, asset recovery and the temporal scope of liability
Confiscation and asset recovery are at the heart of Federal Decree‑Law No. 10 of 2025, which aims not only to punish offenders but also to deprive them permanently of their illicit gains and to protect the financial system from continuing exploitation.
Mandatory confiscation of criminal property
The new anti‑money laundering law obliges courts to order the confiscation of criminal property connected with money laundering, terrorism financing or proliferation financing upon conviction, whether such property constitutes:
- The direct proceeds of the offence; or
- Property used or intended to be used in the commission of the offence; or
- Property that has been converted, transformed or mixed with legitimate assets.
Where direct confiscation is impossible because, for example, the assets have been dissipated, transferred to bona fide third parties, or are located beyond the effective reach of the court, the law empowers, and in certain cases requires, the court to impose a fine equivalent to the value of the criminal property at the time of the offence.
In addition, the Financial Intelligence Unit and competent authorities have been granted strengthened powers to:
- Issue rapid freezing orders over suspicious assets for defined periods without prior notice, including powers to suspend transactions for up to 10 working days and freeze funds for up to 30 days subject to prosecutorial oversight.
- Cooperate with foreign authorities in executing confiscation orders and mutual legal assistance requests, relying on both bilateral treaties and multilateral conventions.
- Use digital tools, including the goAML platform and other analytics systems, to trace complex transaction flows, including those involving virtual assets and decentralised finance structures.
Limitation periods and long‑term exposure
Federal Decree Law No. 10 of 2025 on Anti-Money Laundering and Combating the Financing of Terrorism and Proliferation Financing treats money laundering, terrorism financing and proliferation financing as serious criminal offences, and enforcement actions may proceed in accordance with the limitation periods provided in applicable criminal procedure law and related statutes, subject to the provisions of Federal Decree Law No. 10 of 2025 and the Criminal Procedure Law.
This means that:
- Criminal proceedings for these offences can be initiated after significant periods of time, particularly where new evidence emerges or cross‑border cooperation produces additional information.
- Civil claims arising from such crimes, such as claims for restitution or damages by victims, may, depending on the applicable civil law rules and classification of the underlying acts, benefit from extended enforceability and alignment with criminal proceedings.
- Corporate and individual exposure is therefore long term, and historic transactions remain open to scrutiny where new information or typologies become available to authorities.
Businesses must accordingly adopt record‑keeping and audit practices that anticipate the possibility of investigations many years in the future, maintaining accessible and reliable documentation on clients, counterparties, ultimate beneficial owners and transaction rationales, and ensuring that these can be retrieved promptly in response to requests from competent authorities.
Strategic implications and compliance priorities for United Arab Emirates businesses
The reforms introduced by Federal Decree‑Law No. 10 of 2025 are not confined to criminal lawyers and regulators. They fundamentally change the risk profile for all entities that fall within the definition of financial institutions and designated non‑financial businesses and professions, including virtual asset service providers, law firms, accounting firms, real estate brokers, dealers in precious metals and stones, corporate service providers and other professional intermediaries.
Key strategic implications include the following.
1. Enhanced reliance on circumstantial evidence
Because knowledge can now be inferred from circumstantial evidence, the threshold for enforcement is materially lower. This should lead to:
- More conservative internal risk classifications and client acceptance decisions, particularly for higher‑risk sectors and jurisdictions.
- Closer scrutiny of unusual or complex structures, including special purpose vehicles, trusts and nominee arrangements, especially where funds originate from high‑risk sectors or jurisdictions.
- Heightened attention to documentation of “source of wealth” and “source of funds”, ensuring that explanations are plausible, verifiable and supported by underlying documents.
2. Increased personal exposure for managers and compliance officers
Senior managers, board members and compliance officers who ignore clear red flags, fail to allocate sufficient resources to compliance, or condone circumvention of controls can now more easily be linked, through circumstantial evidence, to knowledge of money laundering schemes. This may support personal prosecution and sanctions under the new framework, in addition to administrative measures by regulators such as prohibition orders and fit‑and‑proper assessments.
3. Elevated corporate sanctions and risk to business continuity
Maximum fines of up to 100,000,000 dirhams or the value of criminal property, combined with possible dissolution and closure of premises, place money laundering offences in the United Arab Emirates at the top tier of corporate risk. Boards should:
- Integrate anti‑money laundering risk assessment into overall enterprise risk management and strategic planning, with clear allocation of responsibility and reporting lines.
- Review insurance arrangements, including directors’ and officers’ liability cover, understanding the limits of cover in relation to intentional misconduct while ensuring adequate provision for investigation and defence costs.
- Ensure that group‑wide policies apply effectively in free zones and across cross‑border structures, taking into account the interaction between onshore United Arab Emirates law and the rules of financial free zones such as the Dubai International Financial Centre and Abu Dhabi Global Market.
4. Long‑term temporal exposure
The treatment of money laundering and related offences as serious crimes, coupled with the extended temporal reach of enforcement, demands a long‑term view. Businesses should:
- Maintain anti‑money laundering records, including customer due diligence files and transaction monitoring alerts, for periods that exceed the bare regulatory minimum where justified by risk and internal policies.
- Regularly revisit historic high‑risk relationships in light of new information, typologies and guidance issued by the United Arab Emirates Financial Intelligence Unit, the Ministry of Economy, the Central Bank of the United Arab Emirates and international bodies.
5. Priority on proactive engagement and remediation
Under the new law, early self‑reporting and meaningful cooperation can significantly mitigate criminal exposure. Where credible concerns arise that past conduct may amount to money laundering or that the business has inadvertently been used as a conduit for criminal funds, it is critical to:
- Seek specialist legal advice promptly, including advice on potential exposure in foreign jurisdictions.
- Conduct an internal investigation under legal privilege where appropriate, with clear terms of reference and documentation of remedial actions.
- Consider voluntary disclosures to the relevant competent authority or the Financial Intelligence Unit through formal suspicious transaction or suspicious activity reports, in line with regulatory guidance from the Ministry of Finance, the Central Bank of the United Arab Emirates and the Ministry of Economy.
6. Virtual assets and technology‑enabled money laundering
The express inclusion of virtual assets, digital systems and encryption technologies within the ambit of money laundering offences requires that entities engaging with or operating as virtual asset service providers build robust controls tailored to decentralised finance, tokenisation and cross‑border blockchain transactions.
This encompasses:
- Deployment of on‑chain analytics tools and blockchain monitoring to identify suspicious patterns and linked addresses.
- Enhanced sanctions screening against targeted financial sanctions lists issued by the United Arab Emirates Cabinet and relevant ministries, including screening of wallet addresses and counterparties.
- Specialised training for staff on crypto‑specific typologies, including mixing services, privacy coins, decentralised exchanges and cross‑chain bridges.
In conclusion, Federal Decree‑Law No. 10 of 2025 solidifies the United Arab Emirates’ position as a jurisdiction with a sophisticated and stringent criminalisation framework for money laundering, terrorism financing and proliferation financing. The law reflects the State’s policy commitment, as articulated by the Ministry of Finance and other competent authorities, to safeguarding the financial system, meeting international benchmarks and reinforcing the country’s standing as a global business hub following its removal from international high‑risk lists.
For business owners, compliance officers and corporate clients, this is not merely a legal development. It is an operational and strategic reality that demands investment in governance, systems, training and continuous legal oversight. Engaging experienced United Arab Emirates legal counsel to assess exposure, design robust compliance programmes and support interactions with regulators and law enforcement is now a critical component of doing business responsibly and sustainably in the United Arab Emirates.
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Article by ProConsult Advocates & Legal Consultants, the Leading Dubai Law Firm providing full legal services & legal representation in UAE courts.
