What is the difference between the UAE AML law and its Executive Regulations?

UAE
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The UAE AML framework operates on two levels. Federal Decree-Law No. 10 of 2025 is the primary statute. It sets out the money laundering, terrorist financing and proliferation financing offences, the institutional architecture, the broad obligations on regulated entities, and the penalties. Cabinet Resolution No. 134 of 2025, the Executive Regulations, sits beneath the law and fills in the operational detail that businesses apply day to day.

In practice, the primary law tells you what must happen and the Executive Regulations tell you how. For example, the law requires customer due diligence and record keeping in general terms, while the Executive Regulations set the specific triggers, including the AED 55,000 and AED 3,500 thresholds, the exact identification data to collect, and the five year retention period. The law expressly directs the Cabinet to issue the Executive Regulations, and both instruments took effect together. When citing a rule, point to the correct instrument, because supervisors expect precise references during inspections.

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.

Guide to Cabinet Resolution No. 134 of 2025

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The AML law sets the offences, the institutional architecture and the penalties. The Executive Regulations set out how regulated businesses actually comply. Federal Decree-Law No. 10 of 2025 is the statute; Cabinet Resolution No. 134 of 2025 is its Executive Regulations, issued by the Cabinet under Article 40 of the statute.

In practice you cite both. The statute tells you that customer due diligence is required and that records must be kept; the Executive Regulations tell you the thresholds, the identification data to collect, the beneficial ownership test and the retention period. A policy that cites only the Decree-Law will be missing the operative detail an inspector asks about, and one citing only the Regulations will be missing the legal basis and the penalties.

Legal Reference (UAE):

· Federal Decree-Law No. 10 of 2025, Article 40: the Cabinet issues the Executive Regulations; Article 19: the core obligations the Regulations then detail.

· Cabinet Resolution No. 134 of 2025, Articles 5 to 25: the operative customer due diligence, controls and record-keeping requirements.

Where the position is finely balanced, document your reasoning and raise it with your compliance officer.

AML terms and definitions