Skip to main content

Understanding Anti-Money Laundering Laws in Dubai: A 2025 Guide

 


Overview of Anti-Money Laundering Laws in Dubai (2025)

Dubai, as part of the United Arab Emirates (UAE), enforces a robust and evolving anti-money laundering (AML) and counter-terrorist financing (CFT) regime. The framework is designed to align with international standards, protect the financial system, and address emerging risks in digital finance and trade.

Key Legislation and Regulatory Bodies

Federal Decree-Law No. 20 of 2018 (as amended by Federal Decree-Law No. 26 of 2021): The principal law governing AML/CFT across the UAE, including Dubai1.

Cabinet Decision No. 10 of 2019 (and amendments): Provides implementing regulations for the above law.

Federal Decree-Law No. 7 of 2024 established the Supreme Committee for AML/CFT to strengthen national coordination and oversight in combating money laundering and terrorist financing.

Virtual Asset Regulations: The Virtual Assets Regulatory Authority (VARA) and the Securities and Commodities Authority (SCA) oversee crypto-related AML compliance, reflecting the UAE’s focus on regulating digital assets and virtual asset service providers (VASPs).

Local Enforcement: Dubai’s Department of Economy and Tourism and Dubai Police investigate and enforce AML compliance at the emirate level.

Supervisory Authorities:

Central Bank of the UAE (CBUAE): Regulates financial institutions (FIs).

Ministry of Economy (MOE): Oversees designated non-financial businesses and professions (DNFBPs), such as real estate agents, precious metals dealers, and lawyers.

Dubai Financial Services Authority (DFSA): Regulates AML compliance in the Dubai International Financial Centre (DIFC), a key financial free zone.

Financial Intelligence Unit (FIU): Receives and analyzes Suspicious Transaction Reports (STRs) via the goAML platform.




Core AML Compliance Requirements

Customer Due Diligence (CDD) & Enhanced Due Diligence (EDD):

Firms must conduct risk-based CDD on all customers, with enhanced checks for high-risk clients and politically exposed persons (PEPs).

Ongoing monitoring of business relationships and transactions is required, especially for sectors like real estate, gold trading, and crypto.

Know Your Customer (KYC):

Mandatory KYC procedures for all financial transactions, including wallet verification and blockchain forensics for VASPs.

Suspicious Transaction Reporting (STR):

Obligatory filing of STRs through the goAML platform for any suspected money laundering or terrorist financing activity.

Ultimate Beneficial Ownership (UBO) Disclosure:

Firms must maintain accurate records of UBOs to prevent the misuse of shell companies.

Appointment of Compliance Officers:

Businesses must appoint a Money Laundering Reporting Officer (MLRO) with direct access to senior management or the Board.

Transaction Monitoring:

Real-time and AI-driven transaction monitoring is encouraged, especially for fintech, payment processors, and digital banks.

Record Keeping:

Firms are required to retain transaction and due diligence records for at least five years.

Sector-Specific Obligations:

Real estate firms must report cash transactions above AED 55,0002.

Crypto exchanges and VASPs must adhere to strict KYC, transaction monitoring, and licensing requirements.

Penalties for Non-Compliance

Corporate fines up to AED 50 million for money laundering offences.

Individual penalties include imprisonment (5–10 years) and/or fines from AED 5 million to AED 50 million.

General AML violations (e.g., failure to file STRs, inadequate CDD) can result in fines from AED 10,000 to AED 1,000,000 and possible imprisonment (1–6 months).

Recent Developments and Strategic Focus (2024–2025)

Removal from FATF Grey List (Feb 2024): The UAE’s improved AML regime led to its removal from the Financial Action Task Force’s Grey List, reflecting enhanced international confidence.

National AML/CFT Strategy (2024–2027): Emphasizes combatting cybercrime, digital payment risks, and trade-based money laundering.

Increased Oversight of Virtual Assets: VARA and SCA cooperation, new digital asset laws, and licensing of VASPs signal a focus on regulating crypto and fintech sectors.

Free Zone Regulations: DIFC (DFSA) and ADGM (FSRA) maintain independent but aligned AML frameworks, with tailored rules for international businesses and heightened scrutiny for crypto transactions

Conclusion

Dubai’s AML laws in 2025 reflect a sophisticated, risk-based, and tech-driven approach, with strong federal and local coordination, sector-specific rules, and severe penalties for non-compliance. Businesses-especially in high-risk sectors-must stay vigilant, update compliance frameworks, and monitor regulatory updates to avoid legal and reputational risks


Get Best Services Anti Money Laundering UAE @ WinguardAML 


Labels:

Comments

Post a Comment

Popular posts from this blog

AML Compliance for DPMS in the UAE

Legal Framework : DPMS are categorized as Designated Non-Financial Businesses and Professions (DNFBPs) under UAE Cabinet Decision No. (10) of 2019. Compliance is required for monetary transactions equal to or exceeding AED 55,000. Key AML Obligations : Risk Assessment : Identify and assess money laundering (ML) and terrorist financing (TF) risks. Policies and Procedures : Establish and update AML/CFT policies to mitigate risks. Customer Due Diligence (CDD) : Conduct due diligence on customers, focusing on risk-based approaches. Suspicious Transaction Reporting (STR) : Report any suspicious activities to authorities. Governance Framework : Appoint an AML Compliance Officer, ensure staff training, and implement internal controls. Record Keeping : Maintain detailed records of transactions and business relationships. Compliance with UN Sanctions : Adhere to directives on international sanctions and fin...
Post a Comment
Read more

What Is The Role of Technology In Anti-Money Laundering (AML) Compliance

  Technology plays a crucial role in Anti-Money Laundering (AML) compliance by enhancing the ability of financial institutions and regulatory bodies to detect, prevent, and report suspicious activities. Here’s how technology contributes to AML compliance: 1. Automation of Compliance Processes Reduces manual workload by automating customer due diligence (CDD) and Know Your Customer (KYC) procedures. Speeds up risk assessments and onboarding processes. 2. AI & Machine Learning for Fraud Detection Identifies patterns of suspicious transactions that human analysts might miss. Enhances anomaly detection by continuously learning from historical records. 3. Transaction Monitoring Systems Real-time monitoring of financial transactions to detect red flags. Uses predefined rules and AI-driven models to identify potential money laundering activities. 4. Blockchain & Cryptographic Technologies Enhances transparency and...
Post a Comment
Read more

Understanding AML Screening and Its Importance in the UAE

  In today’s financial landscape, combating money laundering and terrorist financing has become a global priority. Countries worldwide are implementing stringent measures to ensure that their financial institutions are not exploited for illegal activities. Among these measures, Anti-Money Laundering (AML) screening is a key tool for identifying and preventing the flow of illicit funds. The UAE, as a growing financial hub, plays a pivotal role in this fight. In this blog post, we’ll explore what AML screening is, why it’s crucial, and how it’s being implemented in the UAE.   What is AML Screening? AML screening is a process used by financial institutions, businesses, and governments to detect and prevent the movement of illicit funds. It involves checking customers, transactions, and partners against various databases to ensure they are not associated with criminal activities such as money laundering, terrorist financing, drug trafficking, or organized crime. AML screening...
Post a Comment
Read more