Is money laundering treated as an independent crime under UAE law?

UAE
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1

Yes. UAE law expressly deems money laundering an independent crime. It is treated separately from the predicate offence that generated the illicit proceeds, and it is excluded from the concurrence rules that would otherwise apply under the Crimes and Penalties Law.

The consequence is that the punishment, or non-punishment, of the person who committed the predicate offence does not prevent prosecution and punishment of the person who laundered the proceeds. The two can be pursued as distinct crimes, and a single course of conduct can attract liability for both. This design reflects international standards and closes a gap that offenders previously tried to exploit by arguing the laundering was merely part of the original crime. For businesses, it reinforces that handling or moving suspicious funds is itself a serious offence, independent of whatever predicate crime produced them.

Legal Reference (UAE):

  • Federal Decree-Law No. 10 of 2025, Article 2(2) — money laundering is an independent crime, and the punishment or non-punishment of the predicate offender does not preclude punishment for money laundering.

For more details, consult the full text of Federal Decree-Law No. 10 of 2025 or seek guidance from your AML compliance officer.

A guide to anti-money laundering laws in the UAE

3

Yes. Article 2(2) states that money laundering is an independent crime, and that punishing or not punishing the perpetrator of the predicate offence does not prevent punishment for money laundering.

Article 2(3) goes further: a conviction for the predicate offence is not required to establish that the proceeds came from an illegitimate source, and it is not necessary to prove knowledge of the specific type of predicate offence. Knowledge is an element of the crime but may be inferred from the factual and objective circumstances. Money laundering is also excluded from the concurrence provisions of the Crimes and Penalties Law, so it is punished alongside the predicate offence rather than absorbed into it.

Legal Reference (UAE):

· Federal Decree-Law No. 10 of 2025, Article 2(2): money laundering is an independent crime, excluded from the concurrence rules.

· Federal Decree-Law No. 10 of 2025, Article 2(3): no predicate conviction is needed, and knowledge may be inferred from the circumstances.

For your own circumstances, check your internal AML policy or speak to your compliance officer.

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