Yes. No natural or legal person may carry out financial activities, designated non-financial business and profession activities, or virtual asset service provider activities without first obtaining a licence, registration or enrolment from the competent authority or the relevant supervisory authority. Operating without that authorisation is prohibited.
The requirement is backed by criminal sanction. A person who breaches this licensing rule faces imprisonment and a fine of not less than AED 200,000 and up to AED 10,000,000, or either penalty. This makes proper licensing the entry point to the AML regime: only once a business is authorised does it come under supervision and take on its due diligence, reporting and record-keeping duties. Anyone launching a regulated activity in the UAE should confirm the correct supervisory authority and complete licensing or registration before onboarding a single customer.
Legal Reference (UAE):
- Federal Decree-Law No. 10 of 2025, Article 20 — prohibits regulated activities without a licence, registration or enrolment.
- Federal Decree-Law No. 10 of 2025, Article 32 — penalty of AED 200,000 to AED 10,000,000 for operating without authorisation.
For more details, consult the full text of Federal Decree-Law No. 10 of 2025 or seek guidance from your AML compliance officer.