Which AML law did Federal Decree-Law No. 10 of 2025 replace in the UAE?

UAE
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1

Federal Decree-Law No. 10 of 2025 expressly repealed Federal Decree-Law No. 20 of 2018, which had been the principal UAE statute on anti-money laundering, countering the financing of terrorism and the financing of illegal organisations. Any provision in other legislation that conflicts with the 2025 law is also repealed.

The transition is not a clean sweep of every subordinate instrument. The Executive Regulations, cabinet resolutions and circulars issued under the 2018 law remain effective to the extent they do not conflict with the new Decree-Law, until superseding instruments are issued. This means compliance officers must read older guidance and circulars alongside the 2025 law rather than discarding them outright. The most significant subordinate instrument under the new regime is Cabinet Resolution No. 134 of 2025, which sets out the Executive Regulations. Firms should update policy templates, customer communications and staff training to cite the 2025 law and its regulations rather than the repealed 2018 framework.

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

3

It replaced Federal Decree-Law No. 20 of 2018 on anti-money laundering, combating the financing of terrorism and the financing of illegal organisations. The repeal is in Article 41 of the 2025 law.

The change is not only a renumbering. The 2018 title covered the financing of illegal organisations; the 2025 law addresses proliferation financing instead, and elevates virtual assets, non-profit organisations, beneficial ownership and asset recovery to subjects in their own right. If your policy still cites the 2018 law or Cabinet Decision No. 10 of 2019, it is citing repealed instruments and needs updating.

Legal Reference (UAE):

· Federal Decree-Law No. 10 of 2025, Article 41: the repeal of FDL 20 of 2018.

· Cabinet Resolution No. 134 of 2025, Article 70: repeal of Cabinet Decision No. 10 of 2019.

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

AML/CFT policy, controls and procedures documentation