What are the main changes in the UAE’s 2025 AML law compared with the 2018 law?
Federal Decree-Law No. 10 of 2025 introduces several significant shifts from the 2018 regime. It expressly criminalises proliferation financing alongside money laundering and terrorist financing, brings virtual assets and virtual asset service providers formally within scope, and lowers the evidentiary threshold so that knowledge of illicit origin may be inferred from objective circumstances rather than proven directly.
Penalties are substantially heavier: legal persons now face fines up to AED 100 million, and managers can incur personal criminal liability where an offence results from a breach of their duties. The Financial Intelligence Unit gains power to order freezing of suspect funds, and criminal proceedings for the core offences no longer lapse by prescription. Together these changes signal a tougher enforcement posture and demand a refreshed, risk-based compliance response.
Legal Reference (UAE):
· Federal Decree-Law No. 10 of 2025, Articles 2, 3, 26 and 27 — cover the inferred-knowledge standard, proliferation financing and the increased penalties
For more details, consult the full text of Federal Decree-Law No. 10 of 2025 or seek guidance from your AML compliance officer.