Does UAE AML law apply to virtual assets and cryptocurrency?
Yes. Federal Decree-Law No. 10 of 2025 brings virtual assets squarely within the UAE AML framework. The definition of “Funds” now expressly includes digital and encrypted assets, and the money laundering and terrorism financing offences capture conduct carried out through digital systems, virtual assets, and cryptographic technologies.
Virtual asset service providers are listed alongside financial institutions and designated non-financial businesses as obliged entities, so they must apply customer due diligence, monitor transactions, report suspicions, and keep records. The Executive Regulations require virtual asset service providers to apply due diligence to occasional transactions at or above three thousand five hundred dirhams. The law also criminalises dealing in virtual assets characterised by total anonymity or technologies that obstruct authorities from tracing a transaction or its parties. Operating as a virtual asset service provider without the required licence or registration is prohibited.
Legal Reference (UAE):
· Federal Decree-Law No. 10 of 2025, Article 2 — money laundering through virtual asset channels.
· Federal Decree-Law No. 10 of 2025, Article 30 — dealing in anonymous virtual assets.
For more details, consult the full text of Federal Decree-Law No. 10 of 2025 or seek guidance from your AML compliance officer.