Federal Decree-Law No. (10) of 2025 represents a significant enhancement of the UAE’s existing Anti-Money Laundering and Counter-Terrorist Financing legal framework, reinforcing the country’s commitment to combating money laundering, terrorist financing, and proliferation financing.
Rather than replacing earlier legislation, this Decree-Law builds upon and strengthens the foundations laid under Federal Decree-Law No. (20) of 2018, ensuring closer alignment with FATF Recommendations, international best practices, and the UAE’s National Risk Assessment outcomes.
The law introduces clearer definitions, stronger supervisory powers, improved coordination mechanisms, and enhanced accountability for reporting entities—particularly financial institutions(FIs) and Designated Non-Financial Businesses and Professions (DNFBPs).
Overview of Federal Decree-Law No. 10 of 2025
Federal Decree-Law No. 10 of 2025 enhances the UAE AML/CFT framework by:
- Expanding the scope of predicate offences and financial crime risks
- Strengthening the risk-based approach across all reporting entities
- Enhancing supervisory, inspection, and enforcement powers
- Improving obligations related to beneficial ownership transparency
- Reinforcing reporting, record-keeping, and cooperation requirements
These refinements reflect the UAE’s proactive approach to addressing evolving financial crime threats and maintaining global regulatory credibility.
Why the AML/CFT Framework Was Enhanced
The enhancement of the AML/CFT framework was driven by:
- Increasing sophistication of financial crime techniques
- Growth of digital assets, cross-border structures, and complex ownership models
- FATF mutual evaluation feedback and follow-up requirements
- The need for stronger proliferation financing controls
- UAE’s commitment to remaining a trusted international financial hub
The enhanced framework ensures consistent application of AML/CFT controls across sectors and strengthens preventive, detective, and enforcement mechanisms.
Key Enhancements Under the Enhanced AML/CFT Framework
The enhanced AML/CFT framework under Federal Decree-Law No. 10 of 2025 introduces refinements designed to improve effectiveness rather than create entirely new obligations.
1. Stronger Risk-Based Compliance Expectations
Entities must continuously assess and mitigate risks based on customers, products, transactions, and geographic exposure, with greater emphasis on documented risk assessments.
2. Reinforced Customer Due Diligence and Beneficial Ownership
The law strengthens requirements for identifying customers and ultimate beneficial owners, with stricter expectations for Enhanced Due Diligence (EDD) in higher-risk scenarios.
3. Improved Suspicious Transaction Reporting
Reporting entities are required to ensure timely, high-quality STR and SAR submissions through goAML, with clearer expectations around reporting thresholds.
4. Expanded Supervisory and Enforcement Authority
Supervisory authorities are granted enhanced powers to inspect, investigate, impose penalties, and ensure corrective action.
5. Clearer Governance and Accountability
Boards and senior management are explicitly responsible for AML/CFT oversight, ensuring compliance is embedded at a strategic level.
Comparison: Earlier AML Regulations vs Federal Decree-Law No. 10 of 2025
| Area | Earlier AML Framework (Decree-Law No. 20 of 2018) | Enhanced Framework (Decree-Law No. 10 of 2025) |
| Legislative Scope | AML & CFT focus | AML, CFT and Proliferation Financing |
| Risk-Based Approach | Required but less prescriptive | Stronger emphasis, continuous assessment |
| Beneficial Ownership | Required | Enhanced transparency and verification |
| Supervisory Powers | Defined | Expanded inspection and enforcement authority |
| Governance | General accountability | Explicit board and senior management responsibility |
| Reporting Obligations | STR/SAR requirements | Strengthened quality, timing, and follow-up |
| International Alignment | FATF-aligned | Closer alignment with FATF Immediate Outcomes |
This comparison highlights that the core framework remains intact, but its depth, clarity, and enforcement strength have been significantly enhanced.
Impact on Businesses and DNFBPs
The enhanced AML/CFT framework applies to:
- Banks and financial institutions
- Real estate brokers and developers
- Dealers in precious metals and stones (DPMS)
- Auditors, accountants, and legal professionals
- Trust and company service providers
- Virtual Asset Service Providers (VASPs)
- Casinos and Gaming: Regulated where licensed to operate
- Other High-Risk Sectors like Non-Profit Organizations (NPOs), Trade & Logistics,specifically targeted for monitoring Trade-Based Money Laundering (TBML) risks.
Entities must review policies, strengthen internal controls, and ensure systems are capable of meeting enhanced regulatory expectations.
Importance of AML/CFT Training in UAE
A central requirement under the enhanced framework is ongoing staff awareness and competency. Regulators expect businesses to provide regular AML/CFT/PF training in UAE so employees can:
- Identify red flags effectively
- Understand evolving regulatory expectations
- Apply risk-based controls correctly
- Respond confidently during inspections
Consistent AML compliance training in UAE is now a key indicator of compliance maturity.
Penalties for Non-Compliance
Non-compliance may result in:
- Administrative fines
- License suspension or revocation
- Increased supervisory scrutiny
- Serious reputational damage
These consequences reinforce the importance of proactive compliance management.
How Businesses Can Align with the Enhanced AML/CFT Framework
To remain compliant, businesses should:
- Conduct AML gap assessments against Decree-Law No. 10 of 2025
- Update AML/CFT policies and procedures
- Strengthen customer and transaction risk assessments
- Enhance monitoring and reporting systems
- Deliver periodic AML training to staff and leadership
Conclusion
Federal Decree-Law No. 10 of 2025 marks a strategic enhancement—not a replacement—of the UAE’s AML/CFT framework. It strengthens enforcement, accountability, and risk management while reinforcing the UAE’s zero-tolerance approach to financial crime.To confidently navigate these enhancements and maintain full AML CFT Compliance UAE, Dubai and Abu Dhabi, businesses can rely on Auditac International Consultancy for expert AML advisory, AML audits, AML Software Selection and AML Compliance Program Implementation in Abu Dhabi, and Dubai—helping organizations remain compliant, resilient, and regulator-ready.
