Strengthening the UAE’s Financial Integrity

Area / Subject

Decree-Law No. 20 of 2018

Decree-Law No. 10 of 2025

Document-based Difference

Title / Objective

“Concerning Anti-Money Laundering, Combating the Financing of Terrorism and Illegal Organisations.”

“Concerning Combating Money Laundering, Terrorism Financing, and the Financing of Proliferation.”

2025 law replaces the reference to “Illegal Organisations” with “Financing of Proliferation.”

Definitions Chapter

Defines: Money Laundering, Financing of Terrorism, Illegal Organisations, Funds, Proceeds, Beneficial Owner, Financial Institution, DNFBPs, NPOs, Customer, PEPs.

Expands definitions to include: Proliferation of Armaments, Weapons of Mass Destruction, Virtual Assets, Virtual Asset Service Providers, Supreme Committee, Executive Office for Control and Non-Proliferation, Targeted Financial Sanctions, Asset Recovery.

2025 law broadens definitional scope to cover virtual assets and proliferation-related terms, creating direct linkage with targeted financial-sanctions obligations.

Predicate Offence

Any felony or misdemeanour under UAE law.

Same wording, but expressly includes tax evasion and applies to crimes “whether committed inside or outside the country.”

2025 version expressly enumerates tax evasion and cross-border applicability.

Money-Laundering Crime (Art. 2)

Lists four acts: convert/transfer, conceal/disguise, acquire/use, assist offender.

Contains the same four acts, repeats independence of ML crime and states that knowledge may be inferred from circumstances.

Substantive content identical; 2025 adds digital-system reference (covers encryption and virtual assets).

Financing of Terrorism (Art. 3)

Defined by cross-reference to Federal Law No. 7 of 2014.

Re-written in full: covers direct or indirect provision/collection of funds (including via digital systems and virtual assets) and includes financing of travel for terrorist purposes.

2025 law codifies and broadens the conduct covered and embeds digital context.

Proliferation Financing

Not addressed.

Article 3 (3) introduces criminalisation of financing acts relating to manufacture, possession, transport, sale, or use of weapons of mass destruction and dual-use items.

New offence introduced only in 2025.

Supervisory and National Bodies

Mentions National Committee for AML/CFT under MoF/CBUAE.

Establishes Supreme Committee (Art. 12) and National Committee (Art. 13-15) for national strategy + coordination.

2025 law adds two-tier governance structure and defines their powers in detail.

Financial Intelligence Unit (FIU)

Referred to indirectly under Cabinet Decision; not fully defined in 2018 law.

Article 11 formally establishes an independent FIU within the CBUAE; specifies powers to request information, exchange data domestically and internationally, and maintain secure databases.

2025 law elevates FIU to statutory body with explicit autonomy.

Preventive Measures (Articles 16 – 21 2018)

Art. 16 requires FIs and DNFBPs to: identify risks, assess them, update continuously, retain records, and provide to supervisory authority. Art. 21 requires appointment of Compliance Officer and staff training.

Articles 18-19 (2025) require all entities (including virtual asset service providers) to: identify, understand, evaluate, document, and update crime risks continuously and maintain studies on risk assessment to be provided upon request.

The obligations are restated verbatim but extended to VASPs and PF; 2025 text uses the same risk-based language as 2018 but adds explicit continuous documentation and study maintenance.

Interim Measures / Freezing Authority

No article authorising FIU to suspend or freeze funds directly.

Article 5 – 6: FIU Head may order suspension of suspect transactions for 10 business days and freeze funds for 30 days without notice; extensions by Public Prosecution.

New enforcement mechanism granted to FIU only in 2025.

Investigative Powers

Not detailed in the 2018 law text.

Articles 6-9 provide procedures for identification, tracking, freezing, seizure, confiscation, access to records, and undercover operations.

2025 law codifies investigation procedures previously left to other laws.

Disclosure / Border Declaration

Not explicitly in text of 2018 law.

Article 10 imposes disclosure requirement on persons entering or leaving UAE to declare currencies, negotiable instruments, precious metals, and stones.

New direct obligation introduced.

Supervisory Powers and Penalties

General reference; penalties detailed under implementing regulation.

Articles 16-17 detail administrative penalties: warning, fine (AED 10 k – 5 m), suspension, revocation, publication of penalties; permits escalation for repetition.

2025 law codifies penalty scale within primary legislation.

Reporting Suspicious Transactions

Mentioned under Cabinet Decision 10 of 2019 (not in main text).

Article 18 states FIs, DNFBPs and VASPs must report suspicious transactions directly to the FIU without delay.

Requirement moved into main law, removing dependence on regulation.

Beneficial Ownership and Transparency

Defined but brief.

Broader definition linking control “directly or through a chain of ownership or other indirect means,” to be determined by executive regulations.

2025 law expands and clarifies ultimate control concept.

Administrative Structure

One-level (Supervisory Authority).

Multi-level: Supreme Committee, National Committee, FIU, Executive Office for Control and Non-Proliferation.

2025 law formalises national coordination framework.

Record Keeping / Retention

Specified under Cabinet Decision 10 of 2019.

Incorporated under “Preventive Measures, Transparency and Beneficiaries.”

2025 consolidates retention duty into main decree.

Scope of Entities Covered

Financial Institutions and DNFBPs.

Financial Institutions, DNFBPs, Virtual Asset Service Providers, and Non-Profit Organisations.

Coverage expanded under 2025.

Legislative Hierarchy

Implementation through Cabinet Decision No. 10 of 2019.

Requires new executive regulations (explicit references in several articles).

2025 establishes new regulatory basis replacing 2019 decision.