Do UAE anti-money laundering laws apply to virtual asset service providers (VASPs)?

UAE
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Yes. Virtual asset service providers are squarely within the scope of the UAE AML regime. The law defines a VASP as any natural or legal person that, as a commercial activity, conducts one or more virtual asset activities, and it treats them alongside financial institutions and DNFBPs for preventive-measure purposes.

VASPs must meet the same core obligations as other regulated entities, including risk assessment, customer due diligence, targeted financial sanctions implementation, suspicious transaction reporting and record-keeping. They also cannot operate without the required licence, registration or enrolment from the competent authority. The Executive Regulations set out which virtual asset activities are covered and add VASP-specific requirements, and lower CDD thresholds apply to their occasional transactions. Providers dealing in virtual assets that enable total anonymity face specific criminal exposure, so anonymity-enhancing features are a serious red flag rather than a product feature.

Legal Reference (UAE):

  • Federal Decree-Law No. 10 of 2025, Article 19 — core obligations applying to VASPs; Article 20 — licensing requirement.
  • Cabinet Resolution No. 134 of 2025, Articles 4, 35 and 36 — scope of virtual asset activities and VASP-specific obligations.

For more details, consult the full text of Federal Decree-Law No. 10 of 2025 or seek guidance from your AML compliance officer.

AML regulations for virtual asset service providers in the UAE

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Yes, expressly and throughout. Virtual asset service providers sit alongside financial institutions and DNFBPs in nearly every operative obligation: risk assessment, customer due diligence, record-keeping, internal controls, sanctions screening and suspicious transaction reporting. The Executive Regulations define virtual asset activities as exchange between virtual assets and fiat currencies, exchange between types of virtual assets, transfer of virtual assets, safekeeping or administration of virtual assets or of instruments enabling control over them, and provision of financial services related to an issuer’s offer or sale of virtual assets.

Licensing is a threshold requirement rather than an optional step. No person may carry on virtual asset service provider activities without a licence, registration or enrolment from the competent authority or the relevant supervisory authority, and any person conducting such activity, offering related products or services, or performing its transactions from within the State must be licensed, registered or listed as applicable. The customer due diligence threshold for occasional transactions is lower than for financial institutions, at AED 3,500. Terrorist financing is also defined to cover funds made available through digital systems, virtual assets or cryptographic technologies.

Legal Reference (UAE):

· Federal Decree-Law No. 10 of 2025, Article 20, which prohibits carrying on virtual asset service provider activities without a licence, registration or enrolment.

· Cabinet Resolution No. 134 of 2025, Article 4, which defines the virtual asset activities that bring a person within the regime.

· Cabinet Resolution No. 134 of 2025, Article 36, which requires licensing, registration or listing for any person conducting virtual asset service provider activity from within the State and applies the relevant obligations to them.

· Cabinet Resolution No. 134 of 2025, Article 7(3), which sets the AED 3,500 customer due diligence threshold for occasional transactions by virtual asset service providers.

Where the position is finely balanced, document your reasoning and raise it with your compliance officer.

Virtual assets and AML compliance in the UAE