UNITED ARAB EMIRATES Trends and Developments Contributed by: Yasser Omar and Laryssa Perkins, Hadef & Partners LLC
introduces a more robust framework for dealing with emerging technologies like virtual assets and open finance, and substantially strengthens the CBUAE’s supervisory and enforcement powers. All entities and persons subject to the New CBUAE Law have a one-year grace period, until 16 September 2026, to regularise their status and obtain the neces - sary licences. The New CBUAE Law does not, how - ever, apply to financial free zones within the UAE or financial institutions subject to the supervision of the authorities of financial free zones. A Strengthened Combatting Financial Crime Regime Building on its successful removal from the Finan - cial Action Task Force (FATF) “grey list” in February 2024, the UAE enacted Federal Decree-Law No (10) of 2025 Regarding Combating Money Laundering Crimes, Combating the Financing of Terrorism and the Financing of Arms Proliferation (New AML Law), effective from 14 October 2025. The New AML Law is supported by Cabinet Resolution No (134) of 2025 (New AML Executive Regulations), which specifies the procedures, rules, and controls for implementing the provisions of the New AML Law. The New AML Law and New AML Executive Regula - tions (New AML Framework) aim to strengthen the UAE’s existing anti-money laundering (AML) and counter-terrorist financing (CTF) regime, as well as align with the FATF’s framework for combatting arms proliferation financing (CPF). The New AML Frame - work substantively expands the scope of criminalised activities, enhances the powers of regulatory bodies, increases penalties, and explicitly incorporates regu - lations for emerging technologies like virtual assets. This shift reflects the UAE’s commitment to align - ing with the highest international standards, such as those set by FATF, and addressing a more complex and digitised financial landscape. Significant changes under the New AML Framework include the following: • Expanded Criminal Scope: The New AML Frame - work now expressly criminalises arms proliferation financing as a standalone offence, and specifically
identifies terrorist financing, arms proliferation financing and tax evasion as a predicate offence for money laundering. It also recognises that financial crimes can be committed through digital systems and virtual assets, and adds “Operators of Commercial Games” to the list of Designated Non- Financial Businesses and Professionals that must comply with the New AML Framework, including customer due diligence and suspicious transaction reporting obligations, when carrying out any single financial operation or several related operations equal to or exceeding AED11,000. • Further UBO Transparency: The AML Framework seeks to address misuse of nominee structures to obscure ultimate beneficial ownership by requir - ing Nominee Directors and Nominee Shareholders to disclose their status and the identity of their nominator to the company within 15 working days of any change. • No Limitation Periods: The New AML Law reaffirms there is no statute of limitations for criminal pro - ceedings relating to crimes of money laundering, financing terrorism or arms proliferation financing and explicitly extends this position to civil proceed - ings. • Empowered FIU: The Financial Intelligence Unit (FIU) is an independent body established in the Central Bank. The head of the FIU has had its pow - ers significantly enhanced, including the ability to, without prior notice, freeze assets for up to 30 days and suspend transactions for up to ten working days. • Increased Penalties: The New AML Law imposes harsher penalties, with fines for legal entities of up to AED100 million, or the equivalent value for the relevant criminal property, whichever is greater, for money laundering, terrorist financing, or arms pro - liferation financing. The requirement for the court to order the mandatory dissolution of the legal person has now been extended from legal persons con - victed of a crime of terrorism financing to include a legal person convicted of arms proliferation financ - ing. These reforms, coupled with the National Strategy for AML/CTP/CPF (2024-2027) approved by the UAE Cabinet on 2 September 2024, signal a sustained focus on enforcement, particularly ahead of the next
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