Yes. Virtual asset service providers (VASPs) are subject to the same AML/CFT and targeted financial sanctions obligations as other reporting entities. They must implement, without delay, the instructions issued by the Executive Office concerning targeted financial sanctions, screen customers and counterparties against the lists, and freeze matched assets.
VASPs must also register on the Notification Alert System, file freeze and match reports through goAML, and keep records. Given the cross-border and pseudonymous nature of virtual assets, robust screening and transaction monitoring are especially important. Dealing in assets designed to defeat traceability can attract separate criminal liability under the AML law.
Cabinet Resolution No. 74 of 2020, Article 21 — screening, freezing, and reporting obligations apply to reporting entities including VASPs
For more details, consult the full text of Federal Decree-Law No. 10 of 2025 and Cabinet Resolution No. 74 of 2020 or seek guidance from your AML compliance officer.
Yes. Article 19(1)(e) of the AML law places the duty to implement forthwith the instructions of the Executive Office and other competent authorities on targeted financial sanctions on virtual asset service providers alongside financial institutions and DNFBPs.
The obligation is the same in substance: register for alerts, screen against the UAE Local Terrorist List and the UNSC Consolidated List, freeze without delay on a confirmed match, and report through goAML. Two features of the sector make it demanding in practice. Transfers settle quickly, which compresses the time available to act on a match before value moves. And the law separately criminalises dealing in virtual assets characterised by total anonymity, or that prevent or obstruct the authorities from tracing a transaction or its parties, punishable by imprisonment of not less than three months and a fine of not less than AED 50,000, or either.
Legal Reference (UAE):
· Federal Decree-Law No. 10 of 2025, Article 19(1)(e): VASPs must implement TFS instructions forthwith; Article 33: the penalty for violating them.
· Federal Decree-Law No. 10 of 2025, Article 30(2): the offence of dealing in anonymity-enabling virtual assets; Cabinet Resolution No. 134 of 2025, Articles 35 and 36: VASP supervision and obligations.
For your own circumstances, check your internal AML policy or speak to your compliance officer.