AML/CFT guide · United Arab Emirates
UAE AML/CFT Framework — Reference Guide
An overview of the United Arab Emirates' anti-money-laundering and counter-terrorist-financing framework, its supervisory bodies, legislative history, and core obligations.
Last updated 2026-06-20
UAE AML/CFT Framework — Reference Guide
The United Arab Emirates operates a federal anti-money-laundering (AML) and counter-terrorist-financing (CFT) framework supervised by several authorities, with separate regulators for its financial free zones. The operative statute is Federal Decree-Law No. 10 of 2025 (in force 14 October 2025), which repealed and replaced the previous 2018 law and introduced standalone proliferation-financing and virtual-asset coverage. This guide summarises the bodies involved, the legislative history, and the current framework and core obligations.
Supervisory and coordinating bodies
| Body | Role | Notes |
|---|---|---|
| Central Bank of the UAE (CBUAE) | Supervises licensed financial institutions (LFIs); issues AML/CFT guidance; hosts the FIU and the goAML reporting platform | Maintains the public CBUAE Rulebook of AML laws, regulations and guidance (rulebook.centralbank.ae). |
| UAE Financial Intelligence Unit (FIU) | National FIU; receives, analyses and disseminates suspicious transaction/activity reports filed via goAML | Operates within the CBUAE (uaefiu.gov.ae). |
| National Committee for Combating ML/TF & Illegal Organisations (NAMLCFTC) | National coordinating committee chaired by the CBUAE Governor; drives the National AML/CFT Strategy and National Action Plan | Established under Federal Decree-Law No. 7 of 2024, effective 29 July 2024; assumed the mandate of the former Executive Office for AML/CTF. |
| Supreme Committee for Supervising the National Strategy | Strategic oversight body under the Presidential Court; monitors the effectiveness of the National Committee | Created by Federal Decree-Law No. 7 of 2024. |
| Executive Office for Control & Non-Proliferation (EOCN) | Central authority for targeted financial sanctions (TFS): maintains and circulates the UAE Local Terrorist List, implements the UN Consolidated List, and runs the Notification Alert System (NAS) | uaeiec.gov.ae. |
| DFSA (Dubai Financial Services Authority) | Independent AML/CFT and sanctions supervisor for the DIFC financial free zone | Maintains its own AML rulebook; not under the CBUAE. |
| FSRA (Financial Services Regulatory Authority) | Independent AML/CFT and sanctions supervisor for ADGM (Abu Dhabi Global Market) | Maintains its own AML framework; not under the CBUAE. |
| Ministry of Economy & Ministry of Justice | Supervise designated non-financial businesses and professions (DNFBPs) and registrars | The Ministry of Economy supervises real estate, dealers in precious metals and stones, corporate service providers, and auditors. |
The former Executive Office for AML/CTF, established in February 2021 to drive the National AML/CTF Strategy, was superseded in 2024 when its rights and obligations transferred to the National Committee.
Legislative history
| Year | Law / event | What it changed |
|---|---|---|
| 2002 | Federal Law No. 4 of 2002 on Criminalisation of Money Laundering | First federal AML statute; criminalised money laundering; established early reporting and FIU foundations. |
| 2018 | Federal Decree-Law No. 20 of 2018 on AML/CFT & Financing of Illegal Organisations | Repealed Law 4/2002; modernised the framework covering ML/TF offences, the FIU, customer due diligence, and reporting and supervisory powers. |
| 2019 | Cabinet Decision No. 10 of 2019 (Implementing Regulation of Decree-Law 20/2018) | Operational detail: CDD/EDD, the risk-based approach, reporting mechanics, DNFBP obligations, and supervisory enforcement. |
| 2020 | Cabinet Decision No. 74 of 2020 (Terrorism Lists & UNSC implementation) | Core TFS instrument: implementation of the UAE Local Terrorist List and the UN Consolidated List, with freezing obligations. |
| 2020 | Cabinet Decision No. 58 of 2020 (Beneficial Owner Procedures) | Mandatory UBO registers and filing to registrars (25% ownership/voting threshold). |
| 2021 | Executive Office for AML/CTF established (February 2021) | Central body to run the National AML/CTF Strategy and National Action Plan. |
| 2022 | FATF grey-listing (4 March 2022) | UAE added to FATF's "Jurisdictions under Increased Monitoring" over strategic deficiencies; an action plan was agreed. |
| 2024 | FATF grey-list exit (23 February 2024) | UAE removed after completing its action plan. |
| 2024 | Federal Decree-Law No. 7 of 2024 (amending Decree-Law 20/2018) | Governance restructuring: created the National Committee (NAMLCFTC, effective 29 July 2024) and the Supreme Committee; the National Committee replaced the AML/CTF Executive Office. |
| 2025 | Federal Decree-Law No. 10 of 2025 (in force 14 October 2025) | Repealed and replaced Decree-Law 20/2018; added standalone proliferation-financing offences, explicit virtual-asset/VASP coverage, tax evasion as a predicate offence, and corporate penalties up to AED 100 million. |
| 2025 | Cabinet Decision No. 134 of 2025 (Executive Regulations of Decree-Law 10/2025) | Repealed Cabinet Decision 10/2019; implementing regulations for the new statute. |
The UAE was on the FATF grey list from 4 March 2022 to 23 February 2024. Following the exit, the European Union also removed the UAE from its list of high-risk third countries for AML purposes.
Current framework and core obligations
- Statute. Federal Decree-Law No. 10 of 2025 (AML, CFT and Proliferation Financing), in force 14 October 2025, with executive regulations under Cabinet Decision No. 134 of 2025. This replaced Decree-Law 20/2018 and Cabinet Decision 10/2019.
- Customer due diligence. Risk-based customer due diligence, enhanced due diligence for higher-risk customers (including politically exposed persons), and ongoing monitoring, as detailed in the executive regulations and CBUAE guidance.
- Suspicious transaction reporting. LFIs and DNFBPs register in goAML (built by UNODC and used by FIUs in many jurisdictions) and file suspicious transaction/activity reports to the UAE FIU when they have reasonable grounds to suspect proceeds of crime or terrorist financing. CBUAE guidance frames filing as required without delay.
- Beneficial ownership. Under Cabinet Decision No. 58 of 2020, entities maintain UBO and shareholder/partner registers. A beneficial owner is an individual who owns or controls 25% or more of capital or voting rights, or who exercises control by other means. The financial free zones (DIFC and ADGM) operate their own UBO regimes.
- Targeted financial sanctions. Under Cabinet Decision No. 74 of 2020, reporting entities must screen against, and freeze without delay for, two lists: the UN Consolidated List and the UAE Local Terrorist List, the latter a sovereign designation list maintained by the EOCN and published on uaeiec.gov.ae. The EOCN operates a Notification Alert System (NAS) for list updates and also distributes updates via goAML.
- DNFBP coverage. Real estate brokers and agents, dealers in precious metals and stones, auditors and accountants, and company and trust service providers. Virtual asset service providers (VASPs) are expressly in scope under Decree-Law 10/2025.
- Penalties. Administrative and criminal penalties apply. Under Decree-Law 10/2025, corporate penalties reach AED 100 million, alongside expanded enforcement powers and new offences including proliferation financing.
Sources & primary authorities
URLs accessed 2026-06-20.
Legislation and primary authorities
- CBUAE Rulebook — Federal Decree-Law No. 10 of 2025: https://rulebook.centralbank.ae/en/rulebook/federal-decree-law-no-10-2025-regarding-anti-money-laundering-and-combating-financing
- CBUAE Rulebook — Federal Decree-Law No. 7 of 2024 (amending 20/2018): https://rulebook.centralbank.ae/en/rulebook/federal-law-decree-no-7-2024-amending-certain-provisions-federal-law-law-no-20-2018-anti
- CBUAE Rulebook — Federal Decree-Law No. 20 of 2018: https://rulebook.centralbank.ae/en/rulebook/decree-federal-law-no-20-2018-anti-money-laundering-and-combating-financing-terrorism-and
- CBUAE Rulebook — Cabinet Decision 10/2019 (Implementing Regulation): https://rulebook.centralbank.ae/en/rulebook/cabinet-decision-no-10-2019-concerning-implementing-regulation-decree-law-no-20-2018-anti
- CBUAE Rulebook — Cabinet Decision 58/2020 (Beneficial Owner): https://rulebook.centralbank.ae/en/rulebook/cabinet-decision-58-2020-beneficial-owner-procedures
- CBUAE Rulebook — Cabinet Decision 74/2020 (Terrorism Lists & UNSC): https://rulebook.centralbank.ae/en/rulebook/cabinet-decision-74-2020-terrorism-lists-regulation-and-implementation-un-security-council
- CBUAE Rulebook — Guidance for LFIs on Suspicious Transaction Reporting: https://rulebook.centralbank.ae/en/rulebook/guidance-licensed-financial-institutions-suspicious-transaction-reporting
- UAE Legislation portal — Decree-Law 10/2025: https://uaelegislation.gov.ae/en/legislations/3314
- UAE Legislation portal — Executive Regulations of Decree-Law 10/2025 (Cabinet Decision 134/2025): https://uaelegislation.gov.ae/en/legislations/3857
- UAE FIU — AML/CFT Laws & Related Decisions: https://uaefiu.gov.ae/en/more/knowledge-centre/aml-cft-laws-related-decisions/
- UAE FIU — STR Process: https://www.uaefiu.gov.ae/en/stakeholders/reporting-entities/str-process/
- EOCN — UN Page (Local Terrorist List, UN list, NAS, de-listing): https://www.uaeiec.gov.ae/en-us/un-page
- EOCN — Cabinet Decision 74/2020: https://www.uaeiec.gov.ae/en-us/laws-regulations-listing/cabinet-resolution-no-74-of-2020
- Ministry of Foreign Affairs — Executive Office established (24 Feb 2021): https://www.mofa.gov.ae/en/mediahub/news/2021/2/24/24-02-2021-uae-office
- Ministry of Foreign Affairs — National Committee replaces Executive Office (23 Sep 2024): https://www.mofa.gov.ae/en/mediahub/news/2024/9/23/23-9-2024-uae-national-anti-money-laundering2
- Ministry of Economy & Tourism — Targeted Financial Sanctions: https://www.moet.gov.ae/en/targeted-financial-sanctions
- DFSA — AML/CTF & Sanctions Compliance: https://www.dfsa.ae/what-we-do/aml-ctf-sanctions-compliance/summary
This guide is general information, not legal advice, and is current as of 2026-06-20.
Keep this guide current
Monthly sanctions enforcement digest
Regimes change. Get the monthly digest of new designations and enforcement actions — and a heads-up when we publish a downloadable PDF of this United Arab Emirates guide.