Money Laundering Compliance Advice in the United Arab Emirates: A Comprehensive Framework Against Financial Crime and Regulatory Challenges

Money Laundering Compliance Advice in the United Arab Emirates: Integrated Defence against Financial Crime, Sanctions Breaches, Privacy Violations and Regulatory Investigations

Estimated reading time: 10 minutes

Key Takeaways

• Integrated defence framework is mandatory for all entities under the United Arab Emirates regulatory environment.
• Federal Decree-Law No. (10) of 2025 Regarding Combating Money Laundering, the Financing of Terrorism and the Financing of Proliferation establishes the unified legal framework for anti-money laundering, combating the financing of terrorism, and combating proliferation financing, and repeals previous anti-money laundering laws, including Federal Decree-Law No. (20) of 2018.
• Federal Decree-Law No. (45) of 2021 on the Protection of Personal Data regulates the collection, processing, storage and transfer of personal data in the United Arab Emirates, subject to specific exceptions. Separately, Federal Decree-Law No. (34) of 2021 on Combating Rumours and Cybercrimes criminalises unauthorised access to information technology systems and serious privacy violations.
• A risk-based governance approach, driven by enterprise-wide assessments, ensures senior management accountability.
• Non-compliance with obligations under Federal Decree-Law No. (10) of 2025, including targeted financial sanctions obligations, can result in criminal penalties, including fines and imprisonment, as provided for by the law and its executive regulations.

Strategic Context: The Case for a Comprehensive Defence Framework in the United Arab Emirates

The contemporary regulatory environment in the United Arab Emirates requires every financial institution (banks, DNFBPs, VASPs) to operate within an integrated and proactively managed defence framework against financial-crime and compliance risks. These span terrorist financing, proliferation financing, illegal fund transfers, sanctions breaches and more, extending beyond traditional money laundering exposures.

Institutions must calibrate internal controls, governance structures and policies to the most recent standards, particularly those in the new federal anti-money-laundering framework and evolving data-protection regimes.

United Arab Emirates Legal and Regulatory Architecture for Financial-Crime Prevention

Federal Decree-Law No. (10) of 2025: Substantive Offences and Institutional Framework

Federal Decree-Law No. (10) of 2025 Regarding Anti-Money Laundering, and Combating the Financing of Terrorism and Proliferation Financing is now the primary instrument governing these offences. As confirmed by the official legislation portal, it entered into force on 14 October 2025.

Federal Decree-Law No. (10) of 2025 establishes the Financial Intelligence Unit and the roles of supervisory authorities, including the Central Bank of the United Arab Emirates and the Securities and Commodities Authority, with coordination under a Supreme Committee.

Personal Data Protection and Cybercrime Framework

The Federal Decree-Law No. (45) of 2021 on Personal Data Protection regulates data processing across the UAE. Complementing it, Decree-Law No. (34) of 2021 on Combating Rumours and Cybercrimes criminalises unauthorised access and serious privacy violations (cyber-enabled offences).

Money Laundering Compliance Advice: Risk-Based Governance and Core Controls

Enterprise-Wide Risk Assessment and Governance Framework

Cabinet Resolution No. (134) of 2025 mandates a comprehensive risk-based approach for all obliged entities. From a corporate governance standpoint, senior management bears ultimate responsibility for AML/KYC design and effectiveness.

AML/KYC Regulation Guidance: International Alignment, Sanctions and Regulatory Reporting

Sanctions-Screening and Targeted Financial Sanctions

Targeted financial sanctions are codified under Decree-Law No. (10) of 2025, requiring all persons to freeze assets of designated entities. Non-compliance is a criminal offence, punishable by fines starting at AED 20,000 and potential imprisonment (source).

Illegal Fund Transfer Penalties in the United Arab Emirates

Criminal Penalties under Federal Decree-Law No. (10) of 2025

Chapter Twelve of Federal Decree-Law No. (10) of 2025 sets a robust penalty regime linking fines to the value of criminal property, ensuring proportional sanctions for tipping-off, failure to report and large-scale money laundering.

Frequently Asked Questions

• What is Federal Decree-Law No. (10) of 2025?
  It is the foundational AML/CFT legislation in the UAE, consolidating money laundering, terrorist financing and proliferation offences under a single law.
• Who oversees AML compliance in the UAE?
  The Financial Intelligence Unit, the Central Bank, the Securities and Commodities Authority and other sectoral regulators coordinate under a Supreme Committee.
• What are the penalties for non-compliance?
  Penalties under the applicable AML and related legal framework include fines and imprisonment with ranges specified in the Federal Decree-Law No. (10) of 2025 and its executive regulations, including increased corporate fines and personal liability for senior management, with fines proportional to the value of illicit funds.