Does the UAE AML Law apply to virtual assets and cryptocurrency?
Yes. The 2025 AML Law expressly brings virtual assets within its scope. The definition of terrorist financing covers funds provided through digital systems, virtual assets or cryptographic technologies, and the money laundering offence applies regardless of the channel used to move proceeds.
The law also creates specific offences around the misuse of virtual assets. Anyone who promotes, sells, provides services in or deals in virtual assets characterised by total anonymity, or that prevent or obstruct the authorities from tracing a transaction or its parties, can be punished with imprisonment of not less than three months and a fine of not less than fifty thousand dirhams. Operating unlicensed accounts or technologies that allow such concealment is treated the same way.
Virtual asset service providers are regulated entities with the same core obligations as financial institutions, including customer due diligence, record keeping, suspicious transaction reporting and the travel rule for transfers. Operating without the required licence or registration is itself an offence. Compliance teams in this sector should pay particular attention to anonymity enhancing tools and unhosted wallet risks.
Legal Reference (UAE):
ยท Federal Decree-Law No. 10 of 2025, Articles 2 and 3 capture conduct via virtual assets, and Article 30 penalises dealing in anonymity based virtual assets that obstruct tracing
For more details, consult the full text of Federal Decree-Law No. 10 of 2025 or seek guidance from your AML compliance officer.