Introduction

The UAE will undergo its next FATF Mutual Evaluation in 2026 under the new 5th round methodology. This assessment places stronger weight on real world outcomes, enforcement results, beneficial ownership transparency, sanctions implementation, virtual asset oversight and cross border cooperation. This briefing note summarises everything organisations need to understand the UAE’s current AML and CFT landscape and how to prepare for upcoming supervisory expectations.

What is inside the briefing

FATF Mutual Evaluation Framework
Clear explanations of the 40 Recommendations and 11 Immediate Outcomes, how technical compliance is assessed, and how effectiveness is measured. Includes a simple breakdown of what changes in the 5th round and how MENAFATF will apply these standards.

UAE Results and Reforms
A summary of the UAE’s 2020 MER, technical ratings, effectiveness scores, grey list history, action plan progress, and recent upgrades in laws including Federal Law No. 10 of 2025. Includes enforcement trends, penalties across sectors, and supervisory expectations.

What to Expect in 2026
Key focus areas for assessors, evidence firms must be ready to present, updated requirements for beneficial ownership, virtual assets, confiscation and cross border requests, and how the faster 5th round cycle affects planning.

How Themis Supports Readiness
A mapping of Themis tools, screening systems, risk assessments, AI-driven analytics and advisory services to specific FATF Recommendations. Includes guidance for building stronger monitoring, governance and reporting frameworks.

Who this briefing note is designed for

The briefing is written for senior leaders responsible for financial crime risk, compliance and regulatory engagement across:

• Banks and financial institutions
• DNFBPs including real estate, precious metals and stones, legal, audit and company service providers
• Regulators, supervisors and government bodies
• DIFC, ADGM and free zone authorities
• Fintechs, payment firms and virtual asset providers
• Advisory, consulting and legal practices

If your organisation operates in or through the UAE, this briefing provides essential insight for FATF readiness.

Why download this briefing note

• Understand the updated FATF 5th round methodology and how it will be applied in the UAE
• Benchmark your policies, systems, STR reporting processes and governance frameworks against FATF standards
• Identify key gaps in beneficial ownership, risk assessments, sanctions screening and transaction monitoring
• Prepare evidence based documentation that assessors will review
• Support internal planning, budgeting and technology decisions
• Strengthen your organisation’s AML and CFT resilience and demonstrate commitment to global standards

This briefing note gives you a clear, concise and credible foundation for preparing your institution for the 2026 Mutual Evaluation.