UAE 2025 AML Reforms

Spotlight Keywords:
UAE Compliance
Regtech
Regulatory Reporting
Reputational Risk
Risk Mitigation

The UAE’s financial crime regulatory landscape has entered a decisive new phase. On Sunday, Cabinet Resolution No. 134 of 2025, which implements Federal Decree-Law No. 10 of 2025 on AML/CFT, came into effect. Together, the Decree-Law and Resolution marks a far-reaching overhaul of the country’s AML/CFT framework to date, replacing Federal Law No. 20 of 2018 and significantly expanding the UAE’s regulatory framework for combating financial crime.

What does this mean for businesses in the UAE?

For businesses, the new law signals a clear shift toward stricter compliance expectations, more assertive enforcement, and heightened accountability at both institutional and individual levels. The reforms move decisively beyond policy alignment and into practical, enforceable obligations.  

Key Changes at a Glance
Business Impact
The 2025 law expands the scope of primary offences to expressly include proliferation financing, in addition to money laundering and terrorist financing.
Risk assessments, controls, and transaction monitoring must now explicitly address proliferation-related risks.
Maximum penalties have doubled, with a single violation now attracting fines of up to AED 100 million, significantly increasing corporate financial exposure.
AML/CFT failures now represent a more substantial financial and reputational risk.
The law introduces an objective liability test, under which liability may arise where a person knew or ought reasonably to have known that funds were illicit, even without actual knowledge.
“Lack of awareness” is no longer a safe defence; weak controls and poor oversight can themselves create liability.
Managers and senior officers can face fines and imprisonment if offences occur with their knowledge or due to breaches of their duties.
Directors and senior management must actively oversee AML compliance, not merely delegate it.
Providing false Beneficial Ownership information is now punishable by imprisonment and fines starting from AED 20,000.
Companies must ensure BO registers are accurate, current, and defensible.
The 2025 law formally regulates virtual assets, classifying VASPs as regulated entities and subjecting them to Suspicious Transaction Reporting (STR) obligations.
Crypto-related businesses must align with bank-level AML standards; traditional businesses interacting with VASPs must reassess counterparty risk.

Taken together, these reforms reflect the UAE’s continued commitment to strengthening alignment with the FATF Recommendations and demonstrating measurable progress ahead of its next mutual evaluation cycle.  

By broadening the scope of regulated activities, sharpening enforcement tools, and directly addressing emerging risks such as virtual assets and proliferation financing, the UAE is signaling a clear expectation: compliance standards must evolve in step with the sophistication of financial crime risks.

The new law also restructures national AML coordination by introducing a dual oversight framework, strengthening governance and enforcement. For businesses, this means Increased regulatory scrutiny, higher compliance expectations, dual reporting lines, and greater exposure to penalties.

We’ve broken down the key differences between the 2018 and 2025 AML laws below to provide businesses with a clear understanding of how their anti-financial crime efforts will have to evolve in 2026. See here for the full law.

Old Federal Law No. 20 of 2018
New Federal Decree-Law No. 10 of 2025
New Primary Offence and Refined Predicate Offences
  • The 2018 law covered money laundering and terrorist financing as primary offences but did not extend to proliferation financing.
  • It defined a predicate offence broadly as any act constituting a felony or misdemeanor, whether committed within or outside the UAE.
  • The 2025 law expands the scope of primary offences to expressly cover proliferation financing offences in addition to money laundering and terrorist financing.
  • This means that the new law explicitly criminalises providing funds for weapons of mass destruction, including nuclear, biological, chemical or radiological.
  • The definition of a 'predicate offence' for the purpose of establishing a money laundering offence now also specifically includes the crimes of terrorist financing, arms proliferation financing and indirect and direct tax evasion.
Direct Regulation of Virtual Assets
  • The 2018 law did not specifically address virtual assets or virtual asset service providers (VASPs).
  • The 2025 law brings virtual assets into the fold, defining VASPs as regulated entities, and subjecting them to Suspicious Transaction Reporting (STR) requirements.
  • The new law introduces a specific and severe penalty for operating without a valid license or registration, including potential imprisonment.
  • VASPs, including cryptocurrency exchanges and blockchain service providers, are now required to implement the same stringent AML/CFT compliance measures as those applied to banks and designated non-financial businesses and professions (DNFBPs).
DNFBPs Definition Expanded
  • The 2018 law defined DNFBPs as anyone who practiced commercial or professional activities across specific sectors – namely real estate, dealers of precious metals and stones, legal professionals, auditors and accountants, and company and trust service providers (TCSPs).
  • The new law has expanded the definition of DNFBPs to now capture commercial gaming - include persons who operate commercial gaming halls, operate commercial gaming online, operate sports betting, or operate lottery games (“Gaming Operators”).
  • Gaming Operators will need to comply with a host of new legal and regulatory obligations which did not apply to them beforehand, which will be a significant shift for the gaming industry.
Lower Legal Threshold for Offences
  • The 2018 AML law imposed a higher threshold for establishing liability for the primary offences of money laundering and terrorist financing, requiring proof that the person had actual knowledge of the illicit nature of the funds—commonly referred to as a subjective test.
  • The new law lowers this threshold by introducing an objective test, under which liability may arise where a person knew or ought reasonably to have known that the funds were illicit, even in the absence of actual knowledge.
Increased Penalties and Personal Criminal Liability
  • Under the previous AML law, legal entities could be subject to fines of AED 500,000–50 million for committing an offence or AED 200,000–5 million for failure to have the requisite licensing.
  • Dissolution or closure of a legal entity was only possible for terrorist financing or financing illegal organisations.
  • The original law also did not impose criminal liability on managers or representatives for knowingly committing offences or for breaches of their duties.
  • Under the new AML law, penalties have increased so legal entities can now be fined between AED 5 million to 100 million for principal offences, creating a much higher risk exposure. Failure of licensing remains the same at AED 200,000 and 5 million.
  • The new law also provides that courts can now also order the dissolution of legal entities for money laundering.
  • The new law also includes personal criminal liability, meaning that managers of legal entities can now face a fine or imprison if they have knowledge of an offence and breached employment duties.
Greater Emphasis on Beneficial Ownership
  • Under the 2018 UAE AML Law, beneficial ownership was addressed in a more limited and indirect manner.
  • Under the 2025 law, greater emphasis is placed on establishing Beneficial Ownership across corporate and legal arrangements.
  • Providing false Beneficial Ownership information now carries imprisonment plus fines starting at AED 20,000.
  • UBO requirements are more prescriptive under the new law, including companies having to update UBO details more often, and registrars having to verify and publish core company data.
Enhanced EDD Measures
  • The 2018 law requires customer due diligence (CDD) using a risk-based approach, but enhanced due diligence (EDD) was not strongly articulated.
  • EDD triggers were narrower, mainly focusing on PEPs and high-risk countries.
  • The new law reinforces a risk-based approach and enhanced measures for higher-risk relationships. A failure to apply appropriate EDD measures can now more clearly constitute a statutory breach.
  • Under the new law, FIs, DNFBPs, and VASPs must apply EDD whenever there is a higher risk of money laundering, terrorist financing, or proliferation financing. Institutions must justify why EDD was or was not applied.

The UAE’s continued evolution of its anti-financial crime framework signals a more coordinated and deliberate enforcement environment in the year ahead. Enforcement activity was already intensifying prior to the 2025 AML law, alongside sustained government investment in enhanced FIU powers and stronger domestic and international coordination, including cross-border information sharing and mutual legal assistance.

Taken together, these reforms underscore the UAE’s ongoing commitment to strengthening its anti-financial crime framework and aligning with the FATF Recommendations. This represents a key national priority as the country prepares for its next MENAFATF mutual evaluation cycle in 2026. For firms, this heightens the need to demonstrate the effective implementation of AML controls in practice. Further guidance for the private sector is set out in our briefing note on the UAE’s 2026 mutual evaluation, available here.

If you require support in understanding or implementing any aspect of the new Decree-Law or Cabinet Resolution, Themis can assist. We work closely with regulated firms to assess and strengthen AML frameworks, enhance the effectiveness of controls, and address regulatory expectations in practice. Our support also helps firms prepare for increased supervisory scrutiny, including through tool implementation and policy and procedure reviews.  

Download this related publication

Blog Posts

SpotLight

Stay on top of the ever-changing financial crime landscape by accessing the latest information on emerging criminal techniques and the risks associated with carrying out business with particular industries or in particular jurisdictions.

What Businesses Need to Know

December 2025
UAE 2025 AML Reforms: What Businesses Need to Know

The UAE’s 2025 AML/CFT law marks a major regulatory shift, replacing the 2018 framework with stricter compliance, stronger enforcement and greater accountability. With expanded scope, dual oversight and higher penalties, businesses must strengthen AML controls ahead of the 2026 FATF evaluation.

The Evolving Landscape of Financial Crime

December 2025
When AI Breaks the Rules: The Evolving Landscape of Financial Crime

AI is transforming financial crime as much as compliance. The same tools used to detect risk are now automating fraud, laundering and cybercrime at scale. From AI-driven phishing to synthetic identities, our latest report explores how threats are evolving and how organisations can respond.

Behind the Scenes of Scam Call Centres

December 2025
FinCrime Times | Behind the Scenes of Scam Call Centres

Scam call centres now operate like tech startups, using outsourced labour, data-driven tactics and AI to scale fraud globally. Their professional structure makes them hard to shut down, driving huge financial losses and severe emotional harm to victims worldwide.

How Fraudsters Target Holiday Giving

December 2025
Exploiting Goodwill: How Fraudsters Target Holiday Giving

The holiday season drives generosity and year-end giving, but also a surge in charity fraud. In 2024, UK consumers lost over £1.2m to fake charity scams, while charities lose £1.65bn annually. This article explores how these scams work, warning signs, and how to protect yourself.

Uncertainty, Fraud and Knowledge Gaps

November 2025
FinCrime Times | Fraud in the Illegal Wildlife Trade

The illegal wildlife trade generates over US$48 billion annually, driving species extinction, biodiversity loss and ecosystem collapse. As global enforcement intensifies, tackling IWT remains a critical challenge for environmental and financial crime prevention.

Festive Deals Could Cost More Than You Think

November 2025
Steals or Scams? Festive Deals Could Cost More Than You Think

As UK spending surges for Black Friday and Christmas, online scams spike. Fraudsters use fake websites, counterfeit products and AI-enhanced tactics to steal money and personal data. Shoppers must stay vigilant.

Identity fraud and the blurred edges of the self

November 2025
FinCrime Times | Identity fraud and the blurred edges of the self

Identity fraud now extends far beyond data breaches and cloned credit cards. It includes scams that harvest personal information through fake job ads, fabricated profiles that meet onboarding checks, and AI-generated impersonation capable of fooling biometric security.

Key implications after the US lifts sanctions on Belavia

November 2025
Key implications after the US lifts sanctions on Belavia

US Department of the Treasury lifted OFAC sanctions on Belavia on 4 Nov, easing curbs on Belarus’s state airline. Amid EU bans and Boeing route restrictions, analysts warn of higher sanctions evasion and parallel imports risks via Russia. Explore impacts on compliance, due diligence and trade.

The Victims On The other Side Of The Bitcoin

November 2025
FinCrime Times | Pig Butchering Investment Scams

“Pig butchering” is a fast-growing cryptocurrency scam where fraudsters build trusted and sometimes romantic relationships to lure victims into fake investment schemes, ultimately stealing large sums of money.

The Changing Landscape of Drug Trafficking in the Gulf

October 2025
Navigating New Routes: The Changing Landscape of Drug Trafficking in the Gulf

This blog examines the evolving threat of the global illicit drug trade in the Persian Gulf, highlighting four key trends we’re closely monitoring.

Cobalt, Batteries and Electric Vehicles

October 2025
Cobalt, Batteries and Electric Vehicles: Untangling The Global Supply Chain

Cobalt powers modern technology and electric vehicles but is tied to exploitation, corruption, and environmental harm. This article unpacks global cobalt supply chains, from DRC mines to battery factories, and shows how Themis helps businesses identify and manage related ESG risks.

U.S. Commerce Department Unveils Game-Changing Export Control Rule

October 2025
U.S. Commerce Department Unveils Game-Changing Export Control Rule Targeting Affiliates

The U.S. has just tightened its grip on global trade: a new BIS “affiliates rule” now pulls thousands of companies worldwide under U.S. export controls. If ownership links are hidden, you could still be exposed—discover why this game-changing rule is reshaping compliance everywhere.

Essential Reads on Financial Crime

August 2025
Back to School Reading List: Essential Reads on Financial Crime

We’ve handpicked a selection of standout books our team discovered over the summer—perfect picks to kick off the “back-to-school" season. These compelling reads offer deep insight into financial crimes, the systemic vulnerabilities they exploit, and their far-reaching consequences.

The CFO's Guide to Smarter Investments in Financial Crime and Beyond

August 2025
The CFO’s Guide to Smarter Investments in Financial Crime and Beyond

AI is fast becoming a high-ROI tool in financial crime and compliance. From cutting costs and boosting efficiency to enhancing resilience, strategic AI investments are helping CFOs do more with less - transforming risk management and unlocking new value across the financial sector.

The UK's 2025 National Risk Assessment

July 2025
The UK’s 2025 National Risk Assessment on Money Laundering and Terrorist Financing

The UK’s latest National Risk Assessment (NRA) reveals how money laundering and terrorist financing are evolving—and how the UK is fighting back. A vital guide for AML policy, it arms businesses with intelligence to spot risks and stay protected.

Demands Deeper Due Diligence

July 2025
Beyond the Surface: Why OFAC’s 50 Percent Rule Demands Deeper Due Diligence

Many clients have heard of the OFAC 50 Percent Rule but aren’t sure how it affects them. It’s far-reaching, with hidden sanctions risks. This post explains the rule, why it demands deeper due diligence, and steps to identify and mitigate those risks.

UAE Steps Up the Heat on Dirty Money

June 2025
UAE Steps Up the Heat on Dirty Money

In June, the EU removed the UAE from its list of high-risk jurisdictions from an AML perspective, signaling growing international confidence in the country’s financial crime oversight.

Land Conversion and Financial Crime

February 2025
Risk Assessment Updates

New updates to the Land Conversion and Financial Crime Risk Assessment link environmental harm to financial crime. Cattle rustling in Nigeria and Cameroon is now red-rated, with added risks on carbon credit fraud, child labour, mining corruption, and gold smuggling.

What is Human Trafficking?

October 2024
What is Human Trafficking?

An overview of modern slavery, distinguishing between human trafficking, smuggling, and forced labor. It highlights the global prevalence of exploitation and the importance of understanding these definitions to combat such crimes.

Ensuring Financial Transparency in Dubai Real Estate

August 2024
Ensuring Financial Transparency in Dubai Real Estate

Dubai’s $160B foreign-owned real estate market faces money laundering risks. The UAE now requires reporting of property deals over AED 55K via REAR. Criminals like Daniel Kinahan have exploited property to hide illicit funds, underscoring the need for strict compliance.

Human Trafficking and the Digital World

August 2024
Human Trafficking & the Digital World

Examines how digital platforms and cryptocurrencies facilitate human trafficking, allowing traffickers to operate anonymously and at scale, posing challenges for law enforcement.

Nexus of Sanctions and Trade-Based Financial Crime in Hong Kong

August 2024
Exploring the Nexus of Sanctions and Trade-Based Financial Crime in Hong Kong

Investigates how sanctions intersect with trade-based financial crimes in Hong Kong, highlighting the complexities businesses face in navigating regulatory compliance.

The Hidden Harm of Financial Crimes on Mental Health

May 2024
The Hidden Harm of Financial Crimes on Mental Health

Financial crimes cause more than economic harm—they hit mental health too. UK data shows 60% of fraud victims face distress; Ghana research links corruption to anxiety and depression. This blog calls for tackling both psychological and financial impacts.

The Disproportionate Impact of Environmental Crime on Women

March 2024
International Women's Day 2024

Environmental crime worsens gender inequality, driving violence, trafficking, and hardship for women—especially in regions like the DRC and Peru. Women defenders face abuse, and climate change deepens risks like water scarcity, child marriage, and health threats. Tackling these crimes is key to protecting women’s rights and safety.

Unleashing AI's Potential for Good in Financial Crime Prevention

February 2024
Unleashing AI's Potential for Good in Financial Crime Prevention

AI is transforming financial crime prevention—improving detection, reducing costs, and streamlining compliance. Generative AI and graph networks boost due diligence, while ethical, human-guided use counters criminal misuse. Themis champions tech-human collaboration.

How Fuzzy Is Your Logic?

August 2023
How Fuzzy Is Your Logic?

Explores the application of fuzzy logic in Anti-Money Laundering (AML) systems, emphasising its role in improving name-matching accuracy and reducing false positives, thereby enhancing compliance efficiency.

Tree Thieves

July 2023
Book Review : 'Tree Thieves: Crime and Survival in the Woods' by Lyndsie Bourgon

This book focusses on the challenges faced by law enforcement in North West USA and in British Columbia to combat illegal logging, as well as those of the timber-industry communities established since the late 19th century to maintain meaningful and financially viable lives.

Efforts to Stamp Out Financial Crime

July 2023
Progress Applauded in the UAE's Efforts to Stamp Out Financial Crime

The FATF has highlighted the UAE’s progress in fighting financial crime. Its third enhanced follow-up report upgraded three recommendation ratings for the country, marking a step forward in meeting international standards.

Unravelling the Crisis and FATF's Response?

July 2023
Lebanon's Economic Woes

Lebanon’s economic collapse, fuelled by debt, corruption, and instability, has led to hyperinflation and greater financial crime risk. In Oct 2024, the FATF grey-listed Lebanon. The country pledges a two-year reform plan to boost transparency and restore investor confidence.

A Guide to the Legality of Foreign Cannabis Proceeds in the UK

June 2023
A Guide to the Legality of Foreign Cannabis Proceeds in the UK

The UK treats profits from legal overseas cannabis businesses as criminal property under the Proceeds of Crime Act. Few cases qualify for exceptions, creating a legal grey area—so anyone handling such funds should proceed cautiously and seek legal advice.

Fighting Dirty Money in the UK

April 2023
The Economic Crime Plan 2023-26

The UK’s 2023–2026 Economic Crime Plan commits £400M to tackle money laundering, kleptocracy, and fraud, with reforms to Companies House, crypto, and sanctions. Progress is clear, but critics urge more urgency and funding. Success depends on public-private collaboration.

An Exception To Tattle Tailing

March 2023
An Exception to Tattle Tailing

Suspicious Activity Reports (SARs) are key to fighting financial crime, with 42% of fraud found via tip-offs. Rising UK SARs and account freezes show their impact. Themis urges strong reporting systems and whistleblower protections to foster transparency.

The Murky World of Family, Offshore Companies, and 19th Century London Taverns

March 2023
The Murky World of Family, Offshore Companies, and 19th Century London Taverns

Corrupt elites still exploit the UK property market via offshore structures and relatives to hide assets. Over 18,000 firms remain non-compliant. With cases of children holding luxury homes, Themis calls for tougher enforcement as new UK and FATF guidance target transparency gaps.

Do Countries With Higher Corruption Levels Perform Worse on DEI?

March 2023
Do Countries With Higher Corruption Levels Perform Worse on DEI?

Corruption undermines sustainable development, financial integrity, and DEI. A Themis–Denominator study links lower corruption to higher DEI scores. Marginalised groups, especially women, suffer most. Promoting diversity and transparency is key to fairer societies.

A Reckoning

March 2023
The Reckoning of the Adani Group

Hindenburg Research accuses India’s Adani Group of fraud, alleging stock manipulation, shell firms, and nepotism—halving Gautam Adani’s net worth and shaking investor confidence. The case highlights how financial crime can roil markets and the need for strong due diligence.

The EU's Corporate Sustainability Due Diligence Directive

March 2023
The EU's Corporate Sustainability Due Diligence Directive

Supply chain failures have linked firms like Inditex and Skechers to forced labour and reputational risk. The EU’s CSDDD will require large companies to address human rights and environmental harms. Themis offers tools to assess suppliers and fight modern slavery.

Where are we in the Fight Against Wildlife Trafficking?

March 2023
World Wildlife Day

On World Wildlife Day and CITES’ 50th year, Themis reflects on tackling illegal wildlife trade—the 4th largest financial crime. Laws, AI, forensics, and global cooperation drive change, but shifting demand, like ivory to hippo teeth, shows challenges remain.

Make Sure to Vet Your Dog Breeder

February 2023
Make Sure to Vet Your Dog Breeder

Puppy smuggling in the UK has surged post-pandemic, with organised crime exploiting demand and loopholes to import sick or underage dogs. Despite new laws, enforcement gaps remain. Themis urges buyer vigilance—tools like Themis Search can help spot breeder risks

The Dark Side of Valentine's Day

February 2023
The Dark Side of Valentine's Day

Romance scams rose 30% in 2022, with victims losing £8,234 on average—especially men and those aged 65–74. Scammers use fake profiles and emotional manipulation. Themis urges due diligence in dating; tools like Themis Search can flag risks and help platforms protect users.

Financial Crime in the Russia-Ukraine Crisis

May 2022
Digital Currencies and Financial Crime in the Russia-Ukraine Crisis

Crypto plays roles in both social good and crime—over $50M has aided Ukraine, but bad actors use it to evade sanctions and launder funds, notably via the UAE and Central African Republic. Themis calls for stronger due diligence and compliance to curb misuse.

A Catalyst for Human Trafficking Emerging Risks Facing Ukrainian Refugees

March 2022
A Catalyst for Human Trafficking Emerging Risks Facing Ukrainian Refugees

The Russian invasion of Ukraine has heightened trafficking risks for women and children. Over 2.5M flee, with traffickers exploiting chaos, especially in Moldova, Poland, and Italy. The OSCE urges swift action to warn refugees of false offers and protect them.