As a regional hub for finance, technology and innovation, the UAE faces increasing exposure to Money Laundering, Terrorist Financing and Proliferation Financing risks. The UAE law Federal Decree-Law No. 10 of 2025 regarding Anti-Money Laundering and Combating the Financing of Terrorism and Proliferation Financing (AML/CFT/CPF) and Cabinet Resolution No. (134) of 2025 Regarding the Executive Regulations of the above Federal Decree by Law is a significant step forward in the financial crime compliance landscape. The new AML law refines and introduces significant amendments to strengthen the UAE’s Anti-Money Laundering and Counter Terrorist Financing framework including Combatting Proliferation Financing aligning with the Financial Action Task Force's standards.
At BDO, we are committed to helping businesses manage and mitigate AML/CFT/CPF risks.
Key Changes Introduced Under Federal Decree-Law No. 10 of 2025:
- Formal inclusion of proliferation financing obligations and Tax Evasion, requiring identification, assessment, and mitigation of these risks.
- Lowering of knowledge legal threshold to inferred knowledge based on facts and circumstances
- Expanded coverage by including Commercial Gaming Operators when transacting AED 11,000 or more.
- Inclusion of Virtual Asset Service Providers (VASPs) conducting VA activities or related operations including when conducting on behalf of others.
- Reinforced requirement for a risk-based approach including enterprise-wide risk assessments and customer risk profiling covering proliferation financing and tax evasion risks.
- Broader enforcement powers and administrative penalties for non-compliance.
With evolving regulations and AML/CFT/CPF risks, organizations must:
- Conduct an AML/CFT/CPF Gap Assessment.
- Strengthen governance structures and compliance oversight.
- Update policies and procedures related to AML/CFT/CPF.
- Enhance their enterprise-wide risk assessment risks including risks associated with CPF and Tax evasions.
- Deliver targeted trainings and awareness programs.