The UAE replaced its AML framework in 2025 with Federal Decree-Law No. 10 of 2025 and executive regulations in Cabinet Resolution No. 134 of 2025. Financial institutions and designated non-financial businesses such as real estate agents, dealers in precious metals, corporate service providers, lawyers and accountants must carry out due diligence, report suspicions to the Financial Intelligence Unit and keep records for at least five years. Targeted financial sanctions require any person in the UAE to freeze listed persons' funds within 24 hours.
Who must run an AML programme
The federal AML law and its executive regulations apply to financial institutions, virtual asset service providers and designated non-financial businesses and professions. The listed non-financial categories are commercial gaming operators, real estate brokers and agents, dealers in precious metals and stones, lawyers, notaries and independent legal professionals and accountants, and company and trust service providers.
For businesses supervised by the Ministry of Justice or the Ministry of Economy and Tourism, Cabinet Resolution No. (71) of 2024 sets the administrative penalties for breaches. Entities in the DIFC and ADGM may have different AML supervisors and rulebooks, which should be confirmed for each licence.123
Core AML duties
Customer due diligence is required at the start of a business relationship, on suspicion of a crime and when earlier identification data is doubtful. Financial institutions must also do it for occasional transactions of AED 55,000 or more and occasional wire transfers of AED 3,500 or more; dealers in precious metals and stones for cash transactions of AED 55,000 or more.
Suspicious transactions must be reported to the Financial Intelligence Unit immediately, whatever their value. Lawyers, notaries, other legal professionals and auditors have a limited exemption where professional secrecy applies. Transaction and due diligence records must be kept for at least five years.456
Targeted financial sanctions and governance
Cabinet Decision No. 74 of 2020 requires any person in the UAE to freeze, without prior notice, funds of persons on the UN Sanctions List or the UAE Local Terrorist List within 24 hours of listing, and to notify the Executive Office within five business days. Financial institutions and designated non-financial businesses must screen records and transactions and tell their supervisory authority immediately.
Bribery and other offences sit in the Crimes and Penalties Law (Federal Decree-Law No. 31 of 2021). For private joint stock companies, Ministerial Decision No. 137 of 2024 sets governance rules.78910
| Obligation | Threshold or deadline | Who |
|---|---|---|
| Due diligence on occasional transactions | AED 55,000 or more | Financial institutions |
| Due diligence on occasional wire transfers | AED 3,500 or more | Financial institutions |
| Due diligence on cash transactions | AED 55,000 or more | Dealers in precious metals and stones |
| Suspicious transaction report | Immediately, any value | All reporting entities |
| Record keeping | At least 5 years | All reporting entities |
| Sanctions freeze | Within 24 hours of listing | Any person in the UAE |
| Notify freeze to Executive Office | Within 5 business days | Any person in the UAE |
How it works, step by step
- Confirm whether the business is a financial institution, virtual asset service provider or designated non-financial business, and identify its supervisor.23Relevant supervisory authority (for example Ministry of Economy and Tourism or Ministry of Justice)
- Build due diligence, screening and record-keeping procedures that meet the thresholds above.46Business, overseen by its supervisory authority
- File suspicious transaction reports with the Financial Intelligence Unit without delay.5Financial Intelligence Unit
- On a sanctions match, freeze within 24 hours and notify the Executive Office within five business days.78Executive Office; supervisory authority
No timings or fees are shown unless an official source states them.
Documents usually needed
- AML/CFT risk assessment and policies
- Customer due diligence files and beneficial ownership records
- Sanctions screening logs
- Suspicious transaction report records
- Board-approved governance and compliance policies
Common mistakes
- Assuming AML rules only apply to banks; real estate, gold, corporate services, legal and accounting businesses are covered.
- Relying on policies written for the earlier 2018 framework without checking them against the 2025 law and regulations.
- Screening only against UN lists and missing the UAE Local Terrorist List.
- Discarding records before the five-year minimum.
When the business crosses borders
- Group AML policies need to reflect UAE thresholds, which may differ from those at headquarters.
- UAE sanctions freezing duties apply to any person in the UAE, including branches of foreign groups.
- Funds flows between mainland, DIFC and ADGM entities can involve different supervisors and reporting lines.
What this guide does not yet confirm
These points need checking with a qualified local professional in the United Arab Emirates before you rely on them.
- Bribery provisions in Federal Decree-Law No. 31 of 2021 (public, foreign and private sector bribery, and penalties) could not yet be checked in full.
- The repeal of Federal Decree-Law No. 20 of 2018 and the effective date of the 2025 law were not confirmed from the law text, which could not yet be checked.
- Mandatory insurance requirements for employers and businesses (health, motor and sector cover) were not confirmed run.
- Whistle-blowing protections for private sector employees were not confirmed.
- DIFC (DFSA) and ADGM (FSRA) AML rulebooks were not reviewed.
Sources and review status
Each statement is numbered to the source it was checked against. We use official sources where we can, and each statement says whether it was checked against an official or a secondary source. Sources last checked on 19 October 2026. None of it has been professionally reviewed yet: it is research checked against official and secondary sources by WONE Global, not legal or tax advice.
The federal anti-money laundering and counter-terrorist and proliferation financing law is Federal Decree-Law No. 10 of 2025, with executive regulations in Cabinet Resolution No. 134 of 2025. Federal.
The law text could not yet be checked (server error), so its repeal clause and effective date were not confirmed.
Designated non-financial businesses and professions under the AML executive regulations include commercial gaming operators, real estate brokers and agents, dealers in precious metals and stones, lawyers, notaries, other independent legal professionals and independent accountants, and company and trust service providers. Federal; supervisory authorities may designate further categories.
Cabinet Resolution No. (71) of 2024 sets administrative violations and penalties for breaches of AML and counter-terrorist financing procedures by entities supervised by the Ministry of Justice and the Ministry of Economy. Federal; designated non-financial businesses under those ministries.
Penalty amounts were not reviewed.
Customer due diligence is required on starting a business relationship and, for financial institutions, on occasional transactions of AED 55,000 or more and occasional wire transfers of AED 3,500 or more; dealers in precious metals and stones must apply it to cash transactions of AED 55,000 or more. Federal. Virtual asset service providers: occasional transactions of AED 3,500 or more (Article 7(3)); commercial gaming operators: AED 11,000 or more.
Reporting entities must file suspicious transaction reports with the Financial Intelligence Unit immediately and without delay, regardless of the transaction value. Federal; lawyers, notaries, other independent legal professionals and independent auditors are exempt in certain circumstances covered by professional secrecy (Article 18(2)).
Reporting entities must keep transaction and due diligence records for at least five years from completion of the transaction or end of the business relationship. Federal.
Any person in the UAE must freeze, without prior notice, funds owned or controlled by persons on the UN Sanctions List or the UAE Local Terrorist List within 24 hours of the listing decision. Applies to all persons in the UAE; financial institutions and designated non-financial businesses must also screen records and transactions (Article 21).
A person who freezes funds must notify the Executive Office within five business days, and financial institutions and designated non-financial businesses must immediately notify their supervisory authority. Federal.
The decision defines the Office as the Executive Office of the Committee for Goods Subjected to Import and Export Control.
The federal criminal code is Federal Decree-Law No. 31 of 2021 Promulgating the Crimes and Penalties Law. Federal.
The text retrieved was truncated before the bribery chapter, so bribery article numbers and penalties are not confirmed here.
Ministerial Decision No. 137 of 2024 regulates the Registrar's work, controls on private joint stock companies and their governance rules. Federal; private joint stock companies on the mainland.
Questions on this topic
10 statements on financial crime, sanctions and compliance in the United Arab Emirates
