The UAE has overhauled its financial-crime framework. Federal Decree-Law No. 10 of 2025 on Combating Money Laundering, Terrorism Financing and the Financing of Proliferation took effect on 14 October 2025 and repealed Federal Decree-Law No. 20 of 2018. It keeps the core of the previous regime — a Financial Intelligence Unit, suspicious-transaction reporting and international cooperation — but adds a standalone proliferation-financing framework, brings tax evasion in as a predicate offence, and expressly captures virtual assets, aligning the UAE more closely with FATF standards.
Who should read this
Banks, financial institutions, DNFBPs (real estate, precious metals and stones, auditors, corporate service providers) and virtual asset service providers should review compliance programmes against the new law.
Directly affected
Key facts
- Enacted as Federal Decree-Law No. 10 of 2025 on Combating Money Laundering, Terrorism Financing and the Financing of Proliferation
- Published in the Official Gazette on 30 September 2025; in force from 14 October 2025
- Repeals Federal Decree-Law No. 20 of 2018
- Introduces a standalone framework for proliferation financing, aligning with FATF standards
- Expands predicate offences to include tax evasion
- Expressly brings virtual assets and virtual asset service providers within scope
- Retains the Financial Intelligence Unit, suspicious-transaction reporting and international-cooperation architecture
Executive summary
The 2025 AML/CFT law is a consolidation and upgrade rather than a fresh start. It preserves the enforcement architecture businesses already know — the FIU, the obligation to file suspicious transaction reports, customer due diligence and record-keeping — while closing gaps that mattered for the UAE's FATF standing. The headline additions are a dedicated proliferation-financing regime, the treatment of tax evasion as a predicate offence to money laundering, and explicit coverage of the virtual-asset sector.
What changed
- Proliferation financing. The law establishes standalone offences and obligations targeting the financing of weapons proliferation, a category the 2018 regime did not address as directly.
- Tax evasion as a predicate offence. Proceeds connected to tax evasion can now underpin a money-laundering charge, widening exposure for advisers, intermediaries and financial institutions.
- Virtual assets in scope. Crypto exchanges, wallet providers and platforms facilitating virtual-asset transactions are expressly covered, complementing the VARA and federal virtual-asset frameworks.
- Strengthened enforcement and coordination. The law refines the national AML/CFT institutional framework and enforcement tools to match FATF expectations.
Practical implications
- Programme refresh. AML/CFT policies, risk assessments and STR procedures should be updated to reflect proliferation-financing and virtual-asset obligations.
- Tax-linked risk. Because tax evasion is now a predicate offence, onboarding and transaction monitoring should factor in tax-related red flags.
- Virtual-asset businesses. VASPs should confirm they are registered and supervised, and that their controls meet the federal AML standard as well as VARA/other regulator rules.
- DNFBPs. Real estate agents, dealers in precious metals and stones, auditors and corporate service providers remain squarely in scope and face continued supervisory attention.
Directly affected: banks, financial institutions, DNFBPs and virtual asset service providers.
Effective date: 14 October 2025.
Action items
- Re-run your enterprise AML/CFT risk assessment against the new proliferation-financing and virtual-asset provisions.
- Update STR procedures and monitoring rules to capture tax-evasion red flags.
- Confirm virtual-asset activities are correctly registered and supervised.
- Retrain compliance and front-office staff, and refresh board-level AML reporting.
Enforcement and litigation exposure
Widening predicate offences and a dedicated proliferation-financing regime expand both criminal and regulatory exposure. Firms should expect closer supervisory scrutiny and be ready to evidence a functioning compliance programme; deficiencies can translate into administrative penalties, licensing consequences and, in serious cases, criminal liability for institutions and individuals.
Sources and authorities
Federal Decree-Law No. 10 of 2025 on Combating Money Laundering, Terrorism Financing and the Financing of Proliferation — UAE Legislation Portal
uaelegislation.gov.ae — legislation 3314
Repeals Federal Decree-Law No. 20 of 2018. Published 30 September 2025; in force 14 October 2025.
Instrument details
Instrument: Federal Decree-Law No. 10 of 2025 on Combating Money Laundering, Terrorism Financing and the Financing of Proliferation.
Official Gazette: 30 September 2025. In force: 14 October 2025.
Repeals: Federal Decree-Law No. 20 of 2018. This summary is general guidance; the enacted Arabic text prevails.
Based on Federal Decree-Law No. 10 of 2025 and cross-checked against leading practitioner analyses of the new AML/CFT law. General information only — it does not constitute legal advice, and the enacted Arabic text prevails. For advice on a specific matter, please contact us. Last updated: 2 July 2026.