Can a person be convicted of money laundering in the UAE without a predicate offence conviction?
Yes. Under the 2025 AML Law, a conviction for the predicate offence is not required to establish that proceeds have an illegitimate source. Money laundering is treated as an independent crime, and the punishment or non-punishment of the person who committed the underlying predicate offence does not prevent prosecution for laundering.
The law also lowers the evidentiary burden in a practical sense. It is not necessary to prove knowledge of the specific type or nature of the predicate offence from which the proceeds came. That knowledge, as an element of the crime, may be inferred from the factual and objective circumstances surrounding the conduct, rather than requiring direct proof of intent.
For compliance professionals, this autonomy of the money laundering offence is significant. It means the UAE can pursue those who handle criminal proceeds even where the original crime occurred abroad or cannot be separately prosecuted. It also reinforces why regulated businesses must focus on the indicators of illicit funds in front of them, rather than waiting for proof that a specific crime has been charged elsewhere.
Legal Reference (UAE):
ยท Federal Decree-Law No. 10 of 2025, Article 2 makes money laundering an independent crime that does not require a predicate offence conviction, with knowledge inferable from circumstances
For more details, consult the full text of Federal Decree-Law No. 10 of 2025 or seek guidance from your AML compliance officer.