Federal Decree-Law No. 10 of 2025: what it means for UAE DNFBPs
The UAE replaced its anti-money laundering law in 2025. This guide sets out who is covered, what changed, what every designated business must do, and the penalties, citing the article behind each point.
Last reviewed against the published texts: 15 September 2026
Key dates
Article 42: in force two weeks after publication in the Official Gazette. Article 41 repeals Federal Decree-Law No. 20 of 2018.
The Executive Regulations. They replace Cabinet Decision No. 10 of 2019, which the Central Bank rulebook now marks as repealed.
Article 41(3): instruments issued under the 2018 law stay effective insofar as they do not conflict with the new law, until replaced.
Is the old law still in force?
Is Cabinet Decision No. 10 of 2019 still in force?
No. Cabinet Resolution No. 134 of 2025, the Executive Regulations of the 2025 law, replaced it and has been in force since 14 December 2025. The Central Bank of the UAE rulebook marks Cabinet Decision No. 10 of 2019 as repealed. Policies, procedures and training that still cite it need updating.
Is Federal Decree-Law No. 20 of 2018 still in force?
No. Article 41 of Federal Decree-Law No. 10 of 2025 repeals it, and the 2025 law has been in force since 14 October 2025 under Article 42.
Do circulars and resolutions issued under the 2018 law still apply?
Yes, where they do not conflict with the new law. Article 41(3) keeps instruments issued under the 2018 law effective, insofar as they are consistent with the 2025 law, until they are replaced.
What changed from the 2018 framework
Proliferation financing is now part of the law itself
The 2018 law covered money laundering and the financing of terrorism and illegal organisations. The 2025 law adds Proliferation Financing, defined in Article 1 as providing or collecting funds knowing they will be used for weapons of mass destruction, their means of delivery or related dual-use goods. The obligation is now AML/CFT/CPF, so a risk assessment, policy or training programme that covers only money laundering and terrorist financing is incomplete.
FDL 10/2025, title and Article 1
Commercial gaming operators are designated for the first time
Cabinet Resolution No. 134 of 2025 adds commercial gaming operators, including gaming on vessels and marine craft, for a single transaction or linked transactions of AED 11,000 or more, excluding transactions solely in gaming chips or instruments. Cabinet Decision No. 10 of 2019 had no gaming category.
CR 134/2025, Article 3(1)
New products and technologies must be assessed for proliferation financing risk too
Before launching a new product, practice, delivery channel or technology, a DNFBP must assess the money laundering, terrorist financing and proliferation financing risks it creates. The 2019 rule covered money laundering and terrorist financing only.
CR 134/2025, Article 24; previously CD 10/2019, Article 23
The administrative fine now starts at AED 10,000
Supervisors may fine from AED 10,000 up to AED 5,000,000 per violation. Under the previous regime, as set out in the Executive Office's 2022 sanctions guidance, the range was AED 50,000 to AED 5,000,000. A lower floor gives supervisors room to fine smaller breaches rather than only issue warnings. Repeat violations within a year can attract an incremental fine, and penalties may be published. For DNFBPs supervised by the Ministry of Economy and Tourism or the Ministry of Justice, the fine for a specific breach is set by the list annexed to Cabinet Resolution No. 71 of 2024: 41 violations, each with its own range, from AED 50,000 at the lowest to AED 1,000,000 at the highest, which the Ministry may double for a repeated violation. That resolution was issued under the 2018 law and remains in force under Article 41(3) of the 2025 law insofar as it does not conflict with it; its ranges sit inside the Article 17 limits. No replacement list had been published as of September 2026, and its legal references still use the article numbers of the 2018 law and the 2019 regulation.
FDL 10/2025, Article 17(1)(b), 17(3), 17(4) and 41(3); CR 71/2024, Articles 3 and 5(2) and Annex
Who is a DNFBP
Designation follows the activity, not the trade licence alone. Under Article 3 of Cabinet Resolution No. 134 of 2025, a business is a Designated Non-Financial Business or Profession when it carries out any of these activities:
| Business | When it is designated | CR 134/2025 |
|---|---|---|
| Real estate brokers and agents | When concluding transactions or settlements on behalf of customers for the purchase or sale of real estate. No monetary threshold. | Art. 3(2) |
| Dealers in precious metals and stones | Any single cash transaction, or linked transactions, of AED 55,000 or more. | Art. 3(3) |
| Lawyers, notaries, independent legal professionals and independent accountants | When preparing or carrying out transactions for customers in buying and selling real estate, managing customer funds or accounts, organising contributions for companies, or creating, running, buying or selling legal persons and arrangements. | Art. 3(4) |
| Company and trust service providers | When acting as formation agent, director, secretary or partner, providing a registered or business address, acting as trustee of an express trust, or acting as nominee shareholder, for a customer. | Art. 3(5) |
| Commercial gaming operators | A single or linked transaction of AED 11,000 or more, excluding chip-only transactions. | Art. 3(1) |
| Any other business or profession | Designated by resolution of the Supervisory Authority in coordination with the National Committee. | Art. 3(6) |
Virtual asset service providers and financial institutions are regulated separately, under Articles 4 and 2 of the same resolution. On the mainland and in commercial free zones, the Ministry of Economy and Tourism supervises brokers, dealers, accountants and company service providers, and the Ministry of Justice supervises legal professionals. Firms in the DIFC and ADGM fall under those centres' own AML regimes, which set their own designations and thresholds.
What every DNFBP must do
A documented, current risk assessment
Identify, assess, document and keep updated the money laundering, terrorist financing and proliferation financing risks of the business, and provide the assessment to the supervisor on request.
FDL 10/2025, Art. 19(1)(a)
Customer due diligence from the start of every relationship
DNFBPs apply CDD when a business relationship begins, where a crime is suspected, and where earlier identification data is doubtful. The AED 55,000 and AED 3,500 occasional-transaction thresholds in the same article apply to financial institutions, not to DNFBPs. Existing customers must also be brought up to standard, at times set by materiality and risk.
CR 134/2025, Art. 7 and Art. 13
Enhanced due diligence for high-risk countries
Apply enhanced measures proportionate to the risk for customers and transactions linked to countries the National Committee identifies as high-risk or as having AML/CFT/CPF deficiencies, plus any countermeasures the supervisor requires.
CR 134/2025, Art. 23
Policies approved by senior management
Internal policies, controls and procedures that manage the identified risks, approved by senior management, kept under review and applied across branches and majority-owned subsidiaries.
FDL 10/2025, Art. 19(1)(d)
A compliance officer at management level
Appointed at management level, independent in decision-making, with appropriate competence and experience. Duties include monitoring transactions, deciding on suspicious transaction reports, reviewing systems and reporting to senior management with management's observations and decisions recorded, and running staff training.
CR 134/2025, Art. 22
An independent audit function
An independent audit function to test whether internal policies, controls and procedures are effective and adequate.
CR 134/2025, Art. 21
Targeted financial sanctions, without delay
Implement instructions from the Executive Office and other competent authorities on targeted financial sanctions immediately.
FDL 10/2025, Art. 19(1)(e); Cabinet Decision No. 74 of 2020
No tipping off
Neither the firm nor its directors, officers or employees may tell a customer or anyone else that a suspicious transaction report has been or will be filed, or that an investigation is under way.
CR 134/2025, Art. 19
Records available on request
Keep records, documents and data on domestic and international transactions and make them immediately available to the competent authorities.
FDL 10/2025, Art. 19(1)(f)
Reports filed through goAML
From the Ministry of Economy and Tourism's March 2026 supplemental guidance for each sector. Threshold reports are not risk-based: they are due whenever the trigger is met.
Suspicious transaction and activity reports
Every DNFBP files STRs and SARs with the Financial Intelligence Unit through goAML.
Real Estate Activity Report (REAR)
For freehold purchases or sales paid partly or wholly in cash of AED 55,000 or more, paid in a virtual asset, or funded by money converted from or to a virtual asset. Required even where due diligence is complete and nothing is suspicious.
Dealers in Precious Metals and Stones Report (DPMSR)
For cash transactions of AED 55,000 or more with resident or non-resident individuals, and transactions of AED 55,000 or more with a company or entity whether paid in cash or by wire transfer.
Penalties
| Breach | Penalty | Source |
|---|---|---|
| Administrative fine per violation (any supervised entity) | AED 10,000 to 5,000,000, plus warnings, sector bans, suspension of managers, activity suspension or licence revocation | FDL Art. 17 |
| Administrative fine per listed violation (DNFBPs supervised by the Ministry of Economy and Tourism or the Ministry of Justice) | Set per violation, from AED 50,000 to 1,000,000 depending on the breach; may be doubled when repeated. Examples: no approved AML policy AED 100,000 to 200,000; no STR filed AED 100,000 to 500,000; not freezing funds on a sanctions match AED 500,000 to 1,000,000 | CR 71/2024, Annex and Art. 5(2) |
| Money laundering (individual) | 1 to 10 years' imprisonment and AED 100,000 to 5,000,000, or the value of the criminal property if greater | FDL Art. 26(1) |
| Money laundering, terrorist or proliferation financing (legal person) | AED 5,000,000 to 100,000,000, or the value of the criminal property if greater | FDL Art. 27(1) |
| Tipping off | Imprisonment and a fine of at least AED 50,000, or either | FDL Art. 29(1) |
| Breaching targeted financial sanctions instructions | Imprisonment and a fine of at least AED 20,000, or either | FDL Art. 33 |
| False or misleading beneficial ownership information | Imprisonment and a fine of at least AED 20,000, or either | FDL Art. 35(1) |
How the Ministry of Economy has actually used these powers: every announcement of AML fines on DNFBPs.
A practical checklist
- Confirm whether your activity is designated under Article 3, and who supervises you.
- Update your business risk assessment so it covers proliferation financing, not only money laundering and terrorist financing.
- Replace references to Federal Decree-Law No. 20 of 2018 and Cabinet Decision No. 10 of 2019 in your policies, procedures and training.
- Check that CDD applies from the start of every business relationship, and plan the review of existing customers by risk.
- Confirm your goAML registration and your sanctions notification registration, and that your threshold reports (REAR or DPMSR) are being filed.
- Make sure your compliance officer's reports to senior management record management's observations and decisions.
- Arrange an independent review of your AML/CFT/CPF controls.
AML Compass runs a structured assessment against these requirements for your sector and jurisdiction and produces a report of the gaps, with the article behind each one.
Book a 20-minute demoSources
- Federal Decree-Law No. 10 of 2025, Central Bank of the UAE Rulebook
- Cabinet Resolution No. 134 of 2025, Central Bank of the UAE Rulebook
- Cabinet Decision No. 10 of 2019 (repealed), Central Bank of the UAE Rulebook
- Ministry of Economy and Tourism, AML/CFT guidance for DNFBPs
- Cabinet Resolution No. 71 of 2024, violations and administrative fines, Ministry of Economy and Tourism
This guide summarises published legislation for general information. It is not legal advice, and it does not replace the texts themselves or guidance from your supervisor.