UAE law prohibits any natural or legal person from carrying on financial activities, the business of a DNFBP, or virtual asset service provider activities without first obtaining a licence, registration or enrolment from the competent authority or relevant supervisory authority.
Breaching this requirement is a criminal offence. It is punishable by imprisonment and a fine of not less than AED 200,000 and not more than AED 10,000,000, or either of these penalties. The rule is particularly significant for the virtual asset sector, where unlicensed operators have historically presented elevated money laundering and sanctions-evasion risk. It also matters for professionals who may drift into regulated activity without realising it requires authorisation. Before launching a new service line, businesses should confirm whether it falls within a regulated category and, if so, secure the necessary licence or registration first, because operating without it exposes both the entity and responsible individuals to prosecution.
Legal Reference (UAE):
Federal Decree-Law No. 10 of 2025, Article 20 — licensing requirement; Article 32 — imprisonment and a fine of AED 200,000 to AED 10,000,000, or either, for unlicensed activity.
For more details, consult the full text of Federal Decree-Law No. 10 of 2025 or seek guidance from your AML compliance officer.
Operating without the required authorisation is a criminal offence. It is punishable by imprisonment and a fine of not less than AED 200,000 and not more than AED 10,000,000, or by either of those penalties.
Where a legal person commits the offence through its representatives, directors or agents, it faces a fine of AED 200,000 to AED 10,000,000, and the person responsible for its actual management may be personally punished by imprisonment and a fine if they were aware of the offence and it resulted from a breach of their duties. Administrative consequences run in parallel: the supervisory authority can impose the Article 17 penalties, up to AED 5,000,000 per violation and revocation of the licence. The underlying requirement is in Article 20, which bars any natural or legal person from carrying on financial, DNFBP or virtual asset activity without a licence, registration or enrolment.
· Federal Decree-Law No. 10 of 2025, Article 27(2) and (5): the legal person fine and personal liability of the person responsible for actual management; Article 17: parallel administrative penalties.
For your own circumstances, check your internal AML policy or speak to your compliance officer.