AML and ABC Compliance in UAE — Laws, Obligations & Whats Changed

Understanding AML and ABC Compliance in the UAE

The United Arab Emirates has built one of the region’s most rigorous Anti-Money Laundering (AML) and Anti-Bribery and Corruption (ABC) frameworks, and it continues to actively strengthen that framework rather than treating it as settled. The country’s goal is straightforward: keep its financial system out of reach of terrorist financing, drug trafficking proceeds, and corruption, while preserving its standing as one of the world’s leading financial hubs.

This matters more right now than it might have a year ago. The UAE significantly overhauled its core AML legislation at the end of 2025, and any business still relying on guidance built around the older law is now working from an outdated legal foundation. This guide explains what AML and ABC compliance actually require of UAE businesses today, the legislation currently in force, the institutions responsible for enforcement, and the practical steps businesses need to take to stay compliant.

What Do AML and ABC Actually Mean?

Anti-Money Laundering (AML) refers to the set of laws, regulations, and procedures designed to prevent criminals from disguising illegally obtained funds as legitimate income. In practice, this means identifying suspicious transactions, conducting due diligence on customers, and reporting concerning activity to the relevant authorities before illicit funds can be successfully integrated into the legitimate financial system.

Anti-Bribery and Corruption (ABC) compliance, by contrast, focuses on preventing and detecting bribery and corrupt practices that undermine the integrity of businesses and government institutions. While AML is primarily concerned with the origin and movement of illicit funds, ABC is concerned with the underlying corrupt act itself — the bribe, the kickback, the abuse of position for personal gain — regardless of whether money laundering is also involved.

In practice, the two regimes overlap considerably. Corruption frequently generates proceeds that then need to be laundered, and a business with weak ABC controls is often simultaneously exposed to AML risk. This is why most UAE compliance programs address both together rather than treating them as entirely separate obligations.

The UAE’s AML Legal Framework — What Changed in 2025

For several years, AML compliance in the UAE was governed primarily by Federal Decree-Law No. 20 of 2018 and its accompanying Cabinet Decision No. 10 of 2019. This is still the framework referenced in a great deal of existing guidance and older compliance documentation.

That changed at the end of 2025. The UAE enacted Federal Decree-Law No. 10 of 2025 — formally titled the law on Combating Money Laundering, Terrorism Financing, and the Financing of Proliferation — which came into effect on 14 October 2025 and fully repeals and replaces the previous 2018 law. Shortly after, Cabinet Resolution No. 134 of 2025 came into force on 14 December 2025, replacing the earlier executive regulations under Cabinet Decision No. 10 of 2019 and setting out the detailed implementation rules businesses must now follow.

The new law isn’t simply a renumbering exercise — it introduces several substantive changes that businesses operating in the UAE need to understand:

• Proliferation financing is now a standalone pillar of the framework, sitting alongside money laundering and terrorism financing rather than being folded into a broader “illegal organisations” category as before
• The threshold for establishing liability has been lowered. Previously, liability often depended on demonstrating actual knowledge that funds were illicit — a subjective standard that limited enforcement. The new framework moves toward a more objective standard, making it easier for authorities to act against businesses with weak controls, even without proving direct knowledge of wrongdoing
• Commercial gaming operators — including casinos, online gaming platforms, and e-sports operators — are now formally recognised as Designated Non-Financial Businesses and Professions (DNFBPs) under the regime
• A specific reporting threshold of AED 11,000 now applies to online transactions, whether triggered by a single transaction or cumulatively across linked transactions
• Senior management accountability has been strengthened — senior leadership is now expected to personally approve internal AML policies and directly oversee high-risk relationships, rather than delegating this entirely to compliance staff
• A formal asset recovery mechanism has been introduced, allowing for the confiscation and management of criminal property, with UAE courts now empowered to enforce foreign judicial orders — including provisional measures and asset confiscation — without requiring a separate local investigation

This legislative tightening did not happen in isolation. It follows the UAE’s removal from the FATF “grey list” in February 2024, and authorities are continuing to demonstrate sustained, effective enforcement ahead of an anticipated FATF mutual evaluation expected in 2026. In practical terms, this means UAE regulators are not just updating the law on paper — they are actively increasing supervisory scrutiny and enforcement activity to match it.

Key Obligations Under the Current AML Framework

Regardless of which specific cabinet decision or executive regulation applies at any given moment, the practical compliance obligations facing UAE businesses remain consistent in substance, even as the legal mechanics evolve:

• Risk-based approach (RBA) — businesses must assess their own exposure to money laundering and terrorism financing risk based on their specific customer base, geography, products, and delivery channels, rather than applying a generic, one-size-fits-all control set
• Customer due diligence (CDD) and enhanced due diligence (EDD) — verifying customer identity and understanding the nature of the business relationship, with a higher standard of scrutiny applied to higher-risk customers or transactions
• Ultimate Beneficial Ownership (UBO) transparency — companies must maintain accurate UBO registers, submit ownership details to the relevant authority, and update these records whenever ownership changes occur
• Suspicious transaction reporting — any suspicious or unusual activity must be reported without delay through the goAML platform, the centralised reporting system maintained for the UAE’s Financial Intelligence Unit (FIU)
• Sanctions screening — businesses must screen customers and transactions against UAE and UN sanctions lists, in line with Targeted Financial Sanctions (TFS) obligations issued through Central Bank circulars
• Record-keeping — AML-related records, including customer due diligence files and transaction records, must generally be retained for a minimum of five years

Who Is Required to Comply With AML Regulations in the UAE?

A common misconception is that AML rules apply only to banks. In reality, the UAE’s AML regime extends across a much broader range of businesses, captured under the term Designated Non-Financial Businesses and Professions (DNFBPs). This category includes:

• Real estate brokers and agents, particularly for cash or virtual asset transactions above specified thresholds
• Dealers in precious metals and stones
• Independent accountants and auditors
• Corporate service providers and company formation agents
• Lawyers and legal professionals handling certain types of client transactions
• Virtual asset service providers (VASPs), regulated separately by the Virtual Assets Regulatory Authority (VARA) where applicable
• Commercial gaming operators, now explicitly included following the 2025 reforms

Applicability is determined by the nature of the business activity, not by company size. A small accounting firm handling client funds is just as subject to AML obligations as a large multinational bank — the specific control requirements may differ in scale, but the underlying legal obligation does not disappear simply because a business is small.

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Anti-Bribery and Corruption (ABC) Compliance in the UAE

ABC compliance in the UAE is governed primarily by Federal Decree-Law No. 31 of 2021 on the Issuance of the Crimes and Penalties Law, as amended — a comprehensive penal framework that criminalises bribery and corruption across both the public and private sectors.

The law captures a wide range of corrupt practices, including:

• Bribery of public officials — offering, giving, accepting, or soliciting bribes by public officials or individuals entrusted with public service duties
• Commercial bribery — offering, giving, accepting, or soliciting bribes in connection with private business transactions
• Embezzlement — misappropriating funds or property entrusted to an individual’s care
• Fraud — engaging in deceitful practices to obtain an undue advantage
• Money laundering — concealing or disguising the proceeds of criminal activity, linking ABC enforcement directly back to the broader AML framework

The law establishes clear mechanisms for investigating, prosecuting, and penalising these offences, with the relevant authorities empowered to pursue both administrative and criminal consequences — including substantial fines and imprisonment for individuals found guilty.

Emirate-Level ABC Provisions

Beyond the federal framework, certain emirates maintain their own supplementary regulations. Dubai, for instance, has enacted specific provisions through the Department of Human Resources of the Government of Dubai addressing public sector conduct, while Abu Dhabi maintains its own local law containing specific articles aimed at curbing corrupt practices within the emirate. Businesses operating across multiple emirates should be aware that local-level requirements can supplement — though not replace — the federal ABC framework.

Regulatory Authorities Overseeing AML/ABC Compliance in the UAE

Several institutions share responsibility for supervising and enforcing AML/ABC compliance, each with a distinct sectoral focus:

• Central Bank of the UAE (CBUAE) — supervises financial institutions, issues regulatory circulars, and has the authority to impose sanctions for non-compliance within the banking and financial sector
• Ministry of Economy — oversees AML/ABC compliance for DNFBPs, including real estate brokers and dealers in precious metals, and has significantly increased its enforcement activity in recent years, including a sharp rise in administrative fines
• Securities and Commodities Authority (SCA) — ensures AML/CFT policy compliance within capital markets and securities trading
• Financial Intelligence Unit (FIU) — operates within the Central Bank, receives suspicious transaction reports via the goAML platform, and conducts financial intelligence analysis to support investigations
• Dubai Financial Services Authority (DFSA) and Abu Dhabi Global Market (ADGM) — regulate AML/CFT compliance specifically within their respective financial free zones, maintaining their own detailed rulebooks in addition to federal requirements
• Executive Office for Anti-Money Laundering and Counter-Terrorist Financing — coordinates across agencies and supervises high-risk sectors at a national strategic level

These bodies work in coordination rather than in isolation, reflecting the UAE’s broader strategy of treating financial crime prevention as a shared responsibility between public regulators and private sector businesses.

Practical Compliance Obligations for Businesses

Translating the legal framework into day-to-day practice, UAE businesses subject to AML/ABC regulation are generally expected to maintain the following:

KYC and Customer Due Diligence

Every financial institution and DNFBP must verify customer identity and build a clear risk profile for each customer relationship, applying enhanced scrutiny where the customer, transaction, or geography presents elevated risk.

Suspicious Activity Reporting

Businesses are legally obligated to report suspicious or unusual transactions without delay through the goAML system, regardless of whether the underlying activity is later confirmed as illicit — the obligation is triggered by reasonable suspicion, not certainty.

Employee Training Programs

Organisations should run regular training sessions to keep employees updated on their compliance obligations, particularly given how frequently the underlying legal requirements have shifted in recent years. A program built around the repealed 2018 law is no longer adequate.

Business Risk Assessments

Each organisation needs to design and maintain internal controls specifically tailored to its own money laundering and corruption risk exposure — generic, copied policies that don’t reflect the actual nature of the business are a frequently cited weakness in regulatory reviews.

Failing to meet these obligations can result in significant penalties, including heavy fines, operational restrictions, licence suspension, and in serious cases, frozen bank accounts.

Common Mistakes Businesses Make With AML/ABC Compliance

• Assuming AML doesn’t apply to non-financial businesses — many consulting firms, real estate agents, and accountants mistakenly believe AML obligations are limited to banks
• Appointing a compliance officer without real authority — a Money Laundering Reporting Officer (MLRO) needs genuine decision-making power and direct access to senior management to function effectively
• Relying on generic, templated AML policies — policies that aren’t customised to the company’s actual operations and risk exposure rarely hold up under regulatory scrutiny
• Failing to register on goAML — or neglecting to file suspicious transaction reports when genuinely warranted
• Treating onboarding as the end of due diligence — ongoing monitoring of customers and transactions after onboarding is just as important as the initial checks
• Continuing to reference repealed legislation — businesses still building compliance programs around the 2018 law and its 2019 executive regulations are working from an outdated legal foundation following the 2025 reforms

Why AML and ABC Compliance Matters for UAE Businesses

Protecting the Integrity of the Financial System

Robust AML and ABC compliance protects the stability and safety of the UAE’s financial institutions by preventing the system from being exploited for money laundering or corrupt practices, which over time would erode confidence in the broader financial sector.

Strengthening International Reputation

Compliance with AML and ABC standards directly supports the UAE’s standing as a credible international financial centre. Demonstrated regulatory rigour is a meaningful factor in attracting foreign direct investment, since global investors and financial institutions actively assess a jurisdiction’s AML/CFT track record before committing capital.

Avoiding Severe Penalties

Non-compliance carries real consequences — substantial fines, licence restrictions, frozen accounts, and in serious cases, imprisonment for responsible individuals. Beyond the immediate legal exposure, regulatory action also causes lasting reputational damage that can be difficult to reverse, affecting banking relationships and investor confidence well after the initial penalty is resolved.

Enforcement Trends and What to Expect Going Forward

UAE regulators have demonstrated increasingly proactive enforcement in recent years, with the Ministry of Economy alone issuing well over 200 administrative fines in a single quarter during 2024. The 2025 legislative overhaul — lowering the threshold for establishing liability and expanding senior management accountability — signals that this enforcement trend is intensifying rather than easing.

With an FATF onsite mutual assessment anticipated in 2026, UAE authorities are expected to place particular emphasis on demonstrating the practical effectiveness of their AML/CFT framework, not merely its existence on paper. For businesses, this translates into a clear expectation: compliance programs need to be genuinely operational, regularly tested, and backed by real senior management engagement — not simply a policy document kept in a drawer for when an inspector asks to see it.

Frequently Asked Questions (FAQs)

What is the current AML law in the UAE?

The UAE’s current primary AML legislation is Federal Decree-Law No. 10 of 2025 on Combating Money Laundering, Terrorism Financing, and the Financing of Proliferation, which came into effect on 14 October 2025. It repealed and replaced the previous Federal Decree-Law No. 20 of 2018. The accompanying executive regulations are set out in Cabinet Resolution No. 134 of 2025, effective 14 December 2025.

What is the difference between AML and ABC compliance?

AML (Anti-Money Laundering) compliance focuses on preventing, identifying, and reporting the laundering of proceeds derived from criminal activity. ABC (Anti-Bribery and Corruption) compliance focuses specifically on preventing and detecting bribery and corrupt practices. The two regimes frequently overlap, since corrupt proceeds often require laundering, but they address distinct underlying conduct.

Which businesses need to comply with AML regulations in the UAE?

AML obligations apply to financial institutions and a broad category of Designated Non-Financial Businesses and Professions (DNFBPs), including real estate brokers, precious metals dealers, accountants, auditors, corporate service providers, and — following the 2025 reforms — commercial gaming operators. Applicability depends on business activity, not company size.

What is goAML and why does it matter?

goAML is the centralised platform maintained for the UAE’s Financial Intelligence Unit, used by businesses to register and submit suspicious transaction reports. Registration on goAML is mandatory for regulated entities and DNFBPs, and failing to register or report suspicious activity can result in significant penalties.

What changed in the UAE’s AML framework in 2025?

The 2025 reforms introduced standalone proliferation financing provisions, lowered the threshold for establishing liability, formally classified commercial gaming operators as DNFBPs, set an AED 11,000 reporting threshold for online transactions, increased senior management accountability for AML oversight, and introduced a formal asset recovery and confiscation mechanism.

What is the main law governing bribery and corruption in the UAE?

Anti-Bribery and Corruption compliance in the UAE is primarily governed by Federal Decree-Law No. 31 of 2021 on the Issuance of the Crimes and Penalties Law, as amended, which criminalises bribery and corruption across both the public and private sectors and sets out penalties including fines and imprisonment.

What happens if a business fails to comply with AML or ABC regulations in the UAE?

Non-compliance can result in heavy administrative fines, operational restrictions, suspension or revocation of trade licences, frozen bank accounts, and — in serious cases involving individuals — criminal prosecution and imprisonment. Regulatory action also typically causes lasting reputational damage affecting banking relationships and investor confidence.

How Farahat & Co. Can Assist You

Farahat & Co. provides a comprehensive range of AML and ABC compliance services, tailored to the specific regulatory exposure of each client’s business activity. Our compliance professionals help businesses understand which legal framework applies to their operations, design and implement effective AML/ABC policies aligned with the current 2025 legislation, and maintain ongoing compliance with UAE regulatory requirements as they continue to evolve.

Contact Farahat & Co. today to discuss your AML and ABC compliance requirements.