The UAE’s New Era of Financial Integrity: Understanding Federal Decree-Law No. 10 of 2025
The landscape of financial regulation in the UAE has just undergone a seismic shift. In late 2025, the UAE government enacted Federal Decree-Law No. 10 of 2025, repealing the long-standing 2018 AML Law.
This isn’t just a “patch” or a minor update; it is a comprehensive overhaul designed to position the UAE as a global leader in the fight against financial crime. Whether you are a local startup or a multinational corporation, the rules of the game have changed.
1. The Big Addition: Proliferation Financing (CPF)
For the first time, the UAE has introduced a standalone offense for Proliferation Financing.
- What it means: It is now a specific crime to provide funds, financial services, or assets used for the manufacture or acquisition of nuclear, chemical, or biological weapons (and their delivery systems).
- The Impact: Businesses in logistics, trade finance, and manufacturing must now implement “Counter Proliferation Financing” (CPF) checks alongside their standard AML protocols.
2. Lowering the “Knowledge” Threshold
One of the most significant legal changes is how “intent” is measured.
- Old Standard: Prosecutors often had to prove actual knowledge of a crime.
- New Standard: Knowledge can now be inferred from objective circumstances. If a reasonable person would have suspected the funds were illicit, you—or your business—could be held liable. This “objective test” makes it much easier for authorities to secure convictions.
3. Virtual Assets Move to Center Stage
The 2025 Law explicitly integrates Virtual Asset Service Providers (VASPs) and digital technologies into the framework.
- Anonymity Ban: The law strictly prohibits dealing in or promoting “anonymity-enhanced” virtual assets (privacy coins) that obstruct the ability of authorities to trace transactions.
- Licensing is Mandatory: Operating a VASP without a license now carries heavy criminal penalties, including imprisonment and fines up to 10 million AED.
4. Tougher Penalties & Unlimited Exposure
The financial stakes have reached an all-time high.
- Corporate Fines: Companies found guilty of money laundering can now face fines ranging from 5 million AED to 100 million AED, or the value of the criminal property—whichever is greater.
- Personal Liability: Managers and directors can now be held personally liable for AML failures within their organizations.
- No “Expiration Date”: Crucially, the 2025 Law removes the statute of limitations for money laundering and terrorism financing crimes. These offenses can be prosecuted regardless of how much time has passed.
5. Enhanced Powers for the FIU
The Financial Intelligence Unit (FIU) has been granted “super-powers” to act swiftly:
- Transaction Seizure: The FIU can now suspend suspicious transactions for up to 10 working days without prior notice.
- Extended Freezing: They have the authority to freeze suspected criminal funds for 30 days (extendable), compared to the previous 7-day limit.
Key Takeaways for Businesses
If you are operating in the UAE, the “wait and see” approach to compliance is no longer viable. To stay protected, you should:
- Update Your Risk Assessment: Ensure your internal policies cover “Proliferation Financing” and “Tax Evasion” as predicate offenses.
- Review Virtual Asset Exposure: Even if you aren’t a crypto company, check if your clients or vendors are using digital assets for payments.
- Strengthen UBO Reporting: Providing false information about Ultimate Beneficial Owners is now a standalone criminal offense.
- Train Your Team: Since “reasonable suspicion” is now a legal benchmark, your staff must be experts at identifying red flags.
The Bottom Line: Law No. 10 of 2025 is a clear message from the UAE: the doors are open for legitimate business, but they are slamming shut on financial crime. Compliance is no longer a “check-the-box” exercise—it is a core pillar of business survival.