The UAE's new AML law: what changes for groups trading through Dubai
Federal Decree-Law No. 10 of 2025 widens scope, lowers evidential thresholds and raises penalties. Re-exporters, traders and family-owned groups should look again at their counterparties.
The UAE's Federal Decree-Law No. 10 of 2025 on combating money laundering, terrorist financing and proliferation financing took effect on 14 October 2025, replacing the 2018 law. Commentary from UAE counsel highlights five changes: wider scope including virtual-asset service providers, new offences including proliferation financing, lower evidentiary thresholds, stronger powers for the Financial Intelligence Unit and significantly tougher penalties. Tax evasion is now an explicit predicate offence.
Why it matters beyond banks
Dubai is a trading and re-export hub. Groups that buy, sell or distribute through UAE entities rely on counterparties whose ownership and funds are rarely tested. Under the new law, the cost of not knowing rises.
- Map ultimate beneficial ownership for distributors, agents and trading partners.
- Screen counterparties against sanctions, adverse media and litigation in every jurisdiction where they operate.
- Test pricing and volumes for signs of trade-based money laundering.
- Document the diligence so it can be shown to a regulator or a bank.
Sources
- Hadef & Partners, A new era for AML/CTF/PF in the UAE: Federal Decree-Law No. 10 of 2025, Oct 2025.
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