UAE’s New 2025 AML Law: Major Overhaul of Financial Crime Framework & What Federal Decree-Law No. 10 of 2025 Means for Financial Institutions

Financial crime frameworks around the world are evolving to reflect the increasing complexity of digital finance, cross-border activity, and global enforcement cooperation. The UAE’s latest legislative update reflects this broader shift.

UAE Financial Crime Framework – Key Developments

The UAE’s Federal Decree-Law No. 10 of 2025 updates the country’s financial crime framework, replacing the 2018 legislation and reflecting the evolving nature of global financial activity. The law broadens the scope of financial crime, recognises the increasing role of digital and cross-border transactions, and strengthens the role of the Financial Intelligence Unit (FIU). It also places greater emphasis on effective governance and oversight across regulated sectors.

A broader definition of financial crime

The framework expands the definition of financial crime to include proliferation financing as a standalone offence and clarifies the range of predicate offences, including terrorist financing, tax-related offences, and activities involving digital or virtual assets. It also recognises that financial crime can occur through online platforms, complex ownership structures, and emerging technologies.

Governance and accountability

The law also refines how responsibility may be assessed, allowing authorities to consider whether individuals knew, or reasonably should have known, that funds were connected to unlawful activity. In practice, this reinforces the importance of strong governance, clear escalation procedures, and well-documented decision-making.

What this means for regulated institutions

For regulated institutions, the changes largely reinforce the importance of maintaining robust AML, CTF, and CPF controls and effective monitoring frameworks.

White Water Management Consultants supports organisations across the regulatory lifecycle, from licensing applicability and framework design to post-licensing implementation, gap assessments, and remediation.

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