Does a money laundering conviction require conviction for the predicate offence in the UAE?
No. Federal Decree-Law No. 10 of 2025 treats money laundering as an independent, autonomous crime. Conviction for the predicate offence is not required to establish that the proceeds are illegitimate, and it is not necessary to prove knowledge of the specific type or nature of the predicate offence from which the proceeds were derived.
Knowledge that the funds are criminal proceeds, being an element of the offence, may be inferred from the factual and objective circumstances surrounding the conduct. Whether or not the perpetrator of the predicate offence is punished has no bearing on liability for money laundering. This autonomy makes prosecution more practicable and means regulated entities cannot assume that the absence of an underlying conviction removes money laundering risk from a transaction or relationship.
Legal Reference (UAE):
· Federal Decree-Law No. 10 of 2025, Article 2(2) and Article 2(3) — establish money laundering as an independent offence with inferred knowledge
For more details, consult the full text of Federal Decree-Law No. 10 of 2025 or seek guidance from your AML compliance officer.
No. Federal Decree-Law No. 10 of 2025 treats money laundering as an independent, autonomous crime. Conviction for the predicate offence is not required to establish that the proceeds are illegitimate, and it is not necessary to prove knowledge of the specific type or nature of the predicate offence from which the proceeds were derived.
Knowledge that the funds are criminal proceeds, being an element of the offence, may be inferred from the factual and objective circumstances surrounding the conduct. Whether or not the perpetrator of the predicate offence is punished has no bearing on liability for money laundering. This autonomy makes prosecution more practicable and means regulated entities cannot assume that the absence of an underlying conviction removes money laundering risk from a transaction or relationship.
Legal Reference (UAE):
· Federal Decree-Law No. 10 of 2025, Article 2(2) and Article 2(3) — establish money laundering as an independent offence with inferred knowledge
For more details, consult the full text of Federal Decree-Law No. 10 of 2025 or seek guidance from your AML compliance officer.