What is the difference between money laundering, terrorist financing and proliferation financing?

These three crimes are the core targets of the UAE AML framework, but they are distinct. Money laundering is about disguising the illicit origin of proceeds that already come from a predicate offence. Terrorist financing and proliferation financing are about the purpose to which funds are put, and the funds can come from either legitimate or illegitimate sources.

Under Federal Decree-Law No. 10 of 2025, money laundering covers converting, transferring, concealing, acquiring, possessing or using proceeds known to derive from a crime, or helping the offender evade punishment. Terrorist financing means intentionally providing or collecting funds knowing they will be used for a terrorist act, by a terrorist, or by a terrorist organisation. Proliferation financing means providing funds for weapons of mass destruction, their delivery systems or related dual use goods, or acting under the relevant UN Security Council resolutions. For all three, knowledge can be inferred from the objective circumstances.

Legal Reference (UAE):

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

The inter-relationship of money laundering and terrorist financing

The three offences share machinery but not their logic. Money laundering deals with money that is already dirty: converting, transferring, concealing, disguising, acquiring, possessing or using proceeds of a felony or misdemeanour, or helping the predicate offender escape punishment. The funds come from crime and the purpose is to make them look legitimate.

Terrorist financing runs the other way. It is intentionally providing, collecting or making funds available, directly or indirectly, knowing they will be used for terrorist acts or by a terrorist or terrorist organisation, and the funds may come from an entirely legitimate source. Proliferation financing applies the same idea to weapons of mass destruction, their means of delivery and related materials, including dual-use goods and technologies used for those purposes. For compliance purposes the practical divergence is in detection: laundering is usually found by testing whether funds match the customer’s profile, while terrorist and proliferation financing are more often caught by sanctions screening and by the destination of the money rather than its origin.

Legal Reference (UAE):

· Federal Decree-Law No. 10 of 2025, Article 2, which defines the money laundering offence.

· Federal Decree-Law No. 10 of 2025, Article 3(1) and (2), which define financing of terrorism and provide that the funds may derive from a legitimate or illegitimate source.

· Federal Decree-Law No. 10 of 2025, Article 3(3), which defines the crime of proliferation financing, including in relation to dual-use technologies and goods.

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

The difference between money laundering and terrorist financing