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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.
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.
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.
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.
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.
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