An Analysis Of The UAE’s AML/CFT Institutional Framework And Enforcement Regime

Introduction

The United Arab Emirates has established a comprehensive legal framework to combat Money Laundering (ML), Terrorism Financing (TF), and Proliferation Financing (PF) that aligns with international norms and FATF guidance. The cornerstone of this regime is Federal Decree Law No. 10 of 2025, which superseded previous legislation to address evolving financial threats and enhance the nation’s ability to safeguard its digital and physical economy.

The legal framework implements an “all crimes approach” to money laundering, meaning that handling the proceeds of any felony or misdemeanour is a criminal offence. A conviction for the original predicate offence is not necessary to establish the illicit source of funds, as money laundering is considered an independent offence. A Predicate Offence is defined as “any act constituting a felony or misdemeanor, including terrorism financing, proliferation financing, and evasion of direct and indirect taxes, in accordance with the