Does proliferation financing apply to real estate brokers and gold dealers?

Yes. The duties in Federal Decree-Law 10 of 2025 apply to every DNFBP, and they are written in terms of the Crime, which includes proliferation financing. A firm's exposure depends on its customers and business, which is what its risk assessment has to establish.

What changed on 14 December 2025?

Cabinet Resolution 134 of 2025, the Executive Regulations of the 2025 Decree-Law, came into force, replacing Cabinet Decision 10 of 2019. It includes specific measures for high proliferation financing risk in Article 5(4).

Is the Funds Freeze Report still used?

No. The Executive Office renamed it the Confirmed Name Match Report in its July 2025 amendment to the targeted financial sanctions guidance, and the March 2026 edition keeps that name.

Proliferation Financing for UAE DNFBPs: What the 2025 Framework Requires

Published 18 September 2026 · Last reviewed against the primary sources 18 September 2026

The UAE's AML framework is now AML/CFT/CPF: countering proliferation financing sits in the law beside money laundering and terrorist financing. For a designated business the practical effect is that every programme duty tied to 'the Crime' now covers proliferation financing too. This guide explains what that means and what to check.

What proliferation financing means in UAE law

Article 1 of Federal Decree-Law No. 10 of 2025 defines proliferation financing as providing, collecting or making available funds, directly or indirectly, knowing they will be used in whole or in part for the manufacture, acquisition, development, supply, export, transshipment, brokerage, transport, storage or use of weapons of mass destruction, their means of delivery or related materials, including dual-use technologies and goods used for those purposes. It also covers any other act under the UN Security Council's Chapter VII resolutions on proliferation.

MoET's guidelines note that proliferation financing is a criminal offence, not subject to a statute of limitations, and carries severe penalties.

Source: FDL 10/2025, Article 1; MoET DNFBP Guidelines 2026, section 4.3

Why it now reaches every part of the programme

The Decree-Law defines the Crime as money laundering and its predicate offences, the financing of terrorism, and proliferation financing. The core duties of a DNFBP are written in terms of the Crime: assessing its risks, applying due diligence, and keeping policies approved by senior management. So each of them now has to address proliferation financing.

The Decree-Law has been in force since 14 October 2025, and its Executive Regulations, Cabinet Resolution No. 134 of 2025, since 14 December 2025. A risk assessment or policy written before then, covering only money laundering and terrorist financing, needs revisiting.

Source: FDL 10/2025, Articles 1 and 19(1); CR 134/2025

The specific measures for high proliferation financing risk

Article 5(4) of the Executive Regulations sets out what a firm must do where it identifies high proliferation financing risk, taking proportionate measures that include:

enhanced internal controls to detect and prevent violations, non-implementation or circumvention of the Executive Office's targeted financial sanctions instructions, with ongoing enhanced scrutiny of the business relationship
documented records of the measures taken, available to the authorities on request
periodic review of the internal controls as the level of risk changes

Source: CR 134/2025, Article 5(4)

The compliance officer's review now includes it

The compliance officer must review the firm's anti-money laundering, counter-terrorist financing and proliferation financing systems and procedures, assess their consistency with the law, and report periodically to senior management.

Source: CR 134/2025, Article 22(3)

How it shows up in a DNFBP's business

MoET describes three stages: raising funds, concealing them, and procuring the goods. Concealment often relies on shell and front companies that hide the true beneficial owner, and procurement on falsified shipping documents and fraudulent end-use certificates. For a designated business the exposure is usually indirect: a customer or counterparty that is, or is fronting for, a designated person, or funds and assets such as property or gold that are theirs.

Source: MoET DNFBP Guidelines 2026, sections 4.3.1 and 4.3.2

Targeted financial sanctions: the control that carries most of the load

The Decree-Law requires DNFBPs to implement the Executive Office's targeted financial sanctions instructions forthwith. Cabinet Decision 74 of 2020 requires firms to register for list notifications and to screen customers, potential customers, beneficial owners and transaction parties, regularly and whenever a list changes. The Executive Office's guidance, last amended in March 2026, adds the timings:

a confirmed match is frozen without delay and reported to the Executive Office through goAML as a Confirmed Name Match Report within five business days (this report was called the Funds Freeze Report until July 2025)
a partial match on an existing customer is suspended and reported as a Partial Name Match Report within five business days, pending the Executive Office's instruction
all screening results, including false positives, are kept for at least five years

Source: FDL 10/2025, Article 19(1)(e); Cabinet Decision 74/2020, Article 21; EOCN TFS Guidance, March 2026 edition, paragraphs 35 to 46

A checklist

For a DNFBP reviewing its programme against the 2025 framework:

the business-wide risk assessment names proliferation financing and rates it, with a date after the framework took effect
the AML policy covers proliferation financing and targeted financial sanctions, and is approved by senior management
the firm is registered for Executive Office notifications and screens every party the law names
staff know the confirmed and partial match procedures and the five business day reporting window
the compliance officer's periodic report to senior management covers proliferation financing

Source: Summary of the provisions cited above

See where your firm stands

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Common questions

Does proliferation financing apply to real estate brokers and gold dealers?: Yes. The duties in Federal Decree-Law 10 of 2025 apply to every DNFBP, and they are written in terms of the Crime, which includes proliferation financing. A firm's exposure depends on its customers and business, which is what its risk assessment has to establish.
What changed on 14 December 2025?: Cabinet Resolution 134 of 2025, the Executive Regulations of the 2025 Decree-Law, came into force, replacing Cabinet Decision 10 of 2019. It includes specific measures for high proliferation financing risk in Article 5(4).
Is the Funds Freeze Report still used?: No. The Executive Office renamed it the Confirmed Name Match Report in its July 2025 amendment to the targeted financial sanctions guidance, and the March 2026 edition keeps that name.

Primary sources

A plain reading of the provisions cited, not legal advice. Your firm remains responsible for assessing its own obligations.