How long must AML records be retained in the UAE under the 2025 framework?
The mandatory minimum retention period for AML records in the UAE remains five years under Federal Decree-Law No. 10 of 2025 and Cabinet Resolution No. 134 of 2025. The clock starts from the date the transaction was completed or the business relationship terminated, whichever is later. Competent authorities may require records to be retained for longer in connection with investigations or proceedings, and ADGM and DIFC firms remain subject to a six-year minimum under their own regulators.
The scope of records to be kept is broader under the 2025 Executive Regulations and now expressly includes customer due diligence files, beneficial ownership data, transaction records, internal analyses, screening hits, ongoing monitoring outputs, and any CCTV or ATM recordings used to support those analyses. Records must be stored in a way that allows immediate retrieval upon request from supervisory authorities, the FIU or law enforcement.
Legal Reference (UAE):
- Cabinet Resolution No. 134 of 2025, record-keeping article
- Federal Decree-Law No. 10 of 2025, record-keeping obligations
For more details, consult the full text of Cabinet Resolution 134/2025