AML Compliance Under the UAE's New Anti-Money Laundering Law 2025

26 January 2026

The UAE has introduced a significantly revised anti-money laundering and counter-terrorism financing framework through Federal Decree-Law No. 10 of 2025. This "New AML Law," in force since October 2025, aligns domestic legislation with FATF standards and marks a substantial evolution of the UAE’s financial crime regime. Key changes include the expansion of criminalized conduct, inclusion of Virtual Assets, and a shift in evidentiary standards for prosecutors.

Expanded Scope of AML Criminal Conduct

One of the most notable aspects of the New AML Law is the expansion of the scope of criminalized conduct.

• Weapon Proliferation: The law now expressly criminalizes the financing of proliferation of weapons of mass destruction as a standalone offense.
• Predicate Offenses: The law broadens the concept of predicate offenses, capturing a wider range of serious crimes, including tax-related offenses.
• Increased Exposure: This expansion increases potential exposure for individuals and legal entities whose activities intersect with high-risk jurisdictions or transaction structures.

Digital Assets and AML Compliance Risks

The New AML Law expressly acknowledges that money laundering and related offenses may be committed through electronic systems, digital platforms, and virtual assets.

• VASP Inclusion: Virtual Asset Service Providers (VASPs) are fully brought within the UAE’s AML regulatory perimeter.
• Fintech Hub Integrity: This reflects the UAE’s role as a fintech hub and reinforces expectations regarding licensing, customer due diligence, and suspicious transaction reporting in the virtual asset space.
• Primary Legislation: By embedding these risks into primary legislation, the UAE clarifies that emerging technologies are subject to the same enforcement standards as traditional channels.

Stronger Enforcement and Lower Evidentiary Thresholds

From an enforcement perspective, the New AML Law introduces a significant shift in the evidentiary standard applicable to money laundering offenses.

• Standard of Proof: Prosecutors are no longer required to prove actual knowledge of the illicit origin of funds; liability may be established if a person "knew or should have known" funds were derived from criminal activity.
• Enhanced Powers: The law grants the UAE Financial Intelligence Unit the ability to temporarily freeze assets and suspend transactions for extended periods.
• Faster Intervention: These powers are designed to enable faster intervention and prevent the dissipation of assets during investigations.

Increased Penalties and Corporate Accountability

The New AML Law significantly increases both criminal and administrative penalties for non-compliance.

• Individual & Corporate Fines: Individuals face lengthy imprisonment and substantial fines, while legal entities may face fines reaching tens of millions of dirhams.
• Management Liability: Senior management and board members may face liability where failures in oversight, governance, or internal controls contribute to AML breaches.
• Confiscation: The legislation reinforces corporate criminal liability and allows for the confiscation of assets and instrumentalities connected to the offense.

Asset Recovery and International Cooperation

The law introduces a structured framework for the identification and confiscation of criminal proceeds while safeguarding bona fide third parties.

• Global Collaboration: It strengthens mechanisms for international cooperation, including mutual legal assistance and the execution of foreign confiscation orders.
• Tax Secrecy: Restrictions that previously limited cooperation on grounds such as tax secrecy have been narrowed to enhance cross-border collaboration.

Practical Impact for Regulated Entities

For financial institutions, VASPs, and DNFBPs, the New AML Law necessitates a comprehensive review of existing AML compliance frameworks. Risk assessments, customer due diligence, and beneficial ownership verification must be reassessed in light of these expanded powers.

How MIS Legal Can Help

MIS Legal is well-positioned to assist businesses in assessing the impact of the New AML Law, updating compliance frameworks, and navigating regulatory risks arising from the enhanced UAE AML regime.