Are non-profit organisations covered by the new UAE AML Law?
Yes. Federal Decree-Law No. 10 of 2025 explicitly extends AML, counter-terrorism financing and counter-proliferation financing obligations to non-profit organisations operating in the UAE. The 2025 law and its Executive Regulations require non-profits to undertake risk assessments tailored to their activities, implement governance and internal controls proportionate to their size and risk, screen donors and beneficiaries against the UAE Local Terrorist List and the UN Consolidated List, and report suspicious transactions to the Financial Intelligence Unit through the goAML portal.
The extension reflects FATF Recommendation 8 and addresses a long-standing typology in which non-profits can be misused to channel funds for terrorism financing. Non-profits are now expected to maintain accurate beneficial owner and trustee records, vet large donations and cross-border transfers, and retain records for at least five years. Supervisory authorities, including the relevant Ministry of Community Development and emirate-level charity regulators, oversee the implementation of these obligations.
Legal Reference (UAE):
- Federal Decree-Law No. 10 of 2025, Article on scope
- Cabinet Resolution No. 134 of 2025, provisions on NPOs
For more details, consult the full text of Federal Decree-Law 10/2025