INSITE - UAE- October 2025

UAE ISSUES NEW ANTI-MONEY LAUNDERING LAW FOR 2025

Summary: The United Arab Emirates (UAE) has introduced a new Anti-Money Laundering and Counter-Terrorist Financing law that replaces the previous 2018 framework and further aligns the country with global FATF standards. The new legislation strengthens the overall regulatory system, expands the scope of offences, increases enforcement powers, and raises potential liability for both companies and senior management. This update reflects the UAE’s continued commitment to international best practices and its efforts to reinforce its position as a secure and well-regulated global business hub, ahead of the FATF’s upcoming evaluation in 2026.

In Detail: The UAE has taken another major step toward strengthening its anti-money laundering (AML) and counter-terrorist financing (CTF) regime with the issuance of Federal Decree Law No. 10 of 2025 (the New Law). This new legislation repeals and replaces Federal Decree Law No. 20 of 2018 and reflects the UAE’s ongoing commitment to meeting the Financial Action Task Force (FATF) 40 Recommendations the international benchmark for preventing money laundering (ML), terrorist financing (TF), and proliferation financing (PF).

The New Law follows the European Union’s removal of the UAE from its list of high-risk jurisdictions, further positioning the UAE as a secure, compliant, and globally aligned business hub.

Key Highlights:

1. New Criminal Offences

The New Law expands the list of prosecutable offences, including:

• Criminalization of any unauthorised financing of arms or weapons of mass destruction, including dual-use goods and related technologies.

• A TF offence may now be committed through digital channels, virtual assets, or encryption technologies even where knowledge is implied.

2. Lower Threshold for Proving Offences

Previously, prosecutors had to demonstrate actual knowledge of wrongdoing.Under the New Law:

• Circumstantial or sufficient evidence is now enough.

• Knowledge may be inferred from objective facts, meaning individuals may be liable if they knew or should have known about the unlawful activity.

  
  

This approach mirrors international practices, particularly in the UK, and is expected to make prosecutions more effective.

3. New Oversight Structure

A newly formed Supreme Committee will oversee the National Committee for Combatting Money Laundering and the Financing of Terrorism and Proliferation. Its responsibilities include:

• Preparing and implementing national AML/CTF strategies;

• Assessing risks;

• Facilitating domestic and international information sharing; and

• Proposing regulatory reforms.

4. Expanded Investigative & Enforcement Powers

The Financial Intelligence Unit (FIU) now has broader authority, including the power to:

• Freeze funds for up to 30 days (previously 7 days), with potential extensions by the Public Prosecutor; and

• Suspend transactions for up to ten working days without prior notice.

  
  

Law enforcement agencies at the federal and local levels are also empowered to access any information required to trace criminal property, supporting more robust enforcement.

5. Enhanced International Cooperation & Asset Recovery

The UAE can now enforce foreign confiscation orders and judgments, even without:

• A UAE-based investigation, or

• A ratified convention with the foreign jurisdiction

This change strengthens cross-border asset recovery efforts.

6. Tougher Sanctions & Penalties

The New Law significantly increases penalties, including:

• No upper limit on fines for certain offences, including tipping off

• Fines that may equal or double the value of the criminal proceeds

• Corporate fines increased to AED 100 million for ML/TF/PF offences

• Fines up to AED 10 million for other offences committed by representatives or agents

• Personal liability for managers, including liability arising from failures in oversight or duties

  
  

New penalties apply to activities such as:

• Using or promoting privacy-enhancing virtual asset tools

• Conducting transactions with funds of illegal origin

• Providing false beneficial ownership information

• Allowing third parties to misuse bank or VASP accounts

The New Law marks a significant shift in the UAE’s AML/CTF landscape. Corporations and senior managers face:

• Broader liability exposure

• Stricter expectations around due diligence, internal controls, and governance

• Increased risk of investigation and prosecution

Even businesses not directly subject to full AML/CTF obligations should strengthen their compliance frameworks to reduce risk.

These reforms reflect global trends toward holding companies and their leadership accountable, mirroring enforcement approaches in jurisdictions like the UK.

Key Links: UAE Issues New AML Law to Strengthen Anti-Money Laundering and Counter-Terrorist Financing Framework | DLA Piper

Shifting Burdens and Accountability: The New UAE AML Law - Al Tamimi & Company

DIFC ANNOUNCES PUBLIC CONSULTATION ON AMENDMENTS TO THE REAL PROPERTY LAW AND REGULATIONS, AND THE ENACTMENT OF UPDATED OPERATING REGULATIONS

Summary: The Dubai International Financial Centre (DIFC) has proposed updates to its Real Property Law and related Regulations to improve clarity, fairness, and flexibility within the property framework. In addition, the DIFC has enacted amendments to its Operating Regulations, introducing new powers that allow the DIFC Authority to collect fees from hotels and other establishments serving alcohol within the Centre.

In Detail: DIFC, the leading global financial hub for the Middle East, Africa and South Asia (MEASA), has announced a public consultation on proposed amendments to the DIFC Real Property Law (RPL) and associated Regulations. The proposed changes aim to enhance clarity, fairness and flexibility within the property framework and ensure the regime continues to support the needs of the DIFC community.

In addition, amendments to the Operating Regulations have been enacted to give effect to new powers enabling the DIFC Authority to collect Authority Fees from hotels and other establishments serving alcohol within the Centre.

A DIFC Authority statement noted that the consultation seeks to reinforce a modern, transparent, and adaptable regulatory environment for real property matters.

Key Proposed Amendments

The consultation outlines several updates to the RPL and its Regulations, including:

• Introducing decennial liability for contractors in line with Article 880 of the UAE Civil Code

• Granting statutory powers to the Registrar of Real Property to waive provisions of the RPL where strict application may lead to unfair outcomes

• Extending the lease registration period from 30 to 45 days

• Extending the payment deadline for Freehold Transfer Fees on off-plan sales from 30 to 60 days

• Introducing a penalty for failure to register a lease and removing the fee for lapsing a caveat

Further details regarding the proposed amendments to the RPL and Regulations are available in Consultation Paper No. 3 of 2025, accessible on the DIFC website under the Consultation Papers section. The proposed regulations have been published for a 30-day public consultation period, with the deadline for submitting comments ending on 30 November 2025.

Key Links: DIFC Announces Consultation of Amendments to the DIFC Real Property Law and Regulations and enactment of updated Operating Regulations