Financial Crime law

Key Legislation on Financial Crime in the UAE

1. Federal Decree-Law No. 10 of 2025 on Anti-Money Laundering, Combating the Financing of Terrorism and Proliferation Financing (AML/CFT/CPF Law)

This is the main law in the UAE to fight against illegal money, terrorism financing, and illegal weapons funding.  The law is considered to be the anti-money laundering law of the UAE. The law was introduced on the 30th of September 2025 and took effect from the 14th of October 2025. 

The law repealed and replaced the previous Federal Decree-Law No. 20 of 2018. In addition, the law also complies with FATF standards and takes preventive measures against financing of harmful weapons.

Main offences provided in this Law include:

• Money Laundering (Article 2): 

A person commits money laundering if they know, or there are strong signs, that the money or property comes from a crime, and they intentionally do any of the following:

• Hide, transfer, or dispose of the dirty money with intent to conceal the origin of the funds.
• Conceal or disguise the actual nature of the dirty money, which may include the source of funds, its location, movement, ownership, or control of funds.
• Receive, possess, or use the dirty money even after knowing that the funds are illegally obtained.
• Assists the criminal of the Predicate Offence in escaping punishment thereto.

Money laundering is a separate crime. It does not matter whether the person who committed the original crime is punished or not. They can still be punished for money laundering.

You do not need a conviction for the original crime to prove the money came from an illegal source. You also do not need to know the exact type of crime it came from. Knowledge can be understood from the facts and circumstances of the case.

2. Terrorist Financing (Article 3):

A person commits Financing of Terrorism if they intentionally give, collect, or provide money in any way — directly or indirectly — including through digital systems, virtual assets, or crypto, knowing that the money will be used (fully or partly) for any of the following:

• To carry out a terrorist act.
• To support a terrorist or a terrorist organisation.
• To finance someone’s travel to another country so they can commit, plan, prepare, participate in, or help with a terrorist act, or to provide money for terrorist training.

For this rule:

• The money can come from legal or illegal sources.
• It does not matter whether the money was actually used to commit or attempt a terrorist act.
• It does not need to be linked to a specific terrorist act.
• The crime applies even if the person giving the money is in a different country from the terrorist, the organisation, or the place where the act will happen.

3. Weapons Proliferation Financing (Article 3):

Whoever intentionally does any of the following is considered to have committed Proliferation Financing:

• Provides, collects, or gives money (directly or indirectly) knowing it will be used — fully or partly — for the manufacture, purchase, development, sale, transport, storage, or use of weapons of mass destruction (WMDs), their delivery systems, or related materials, including dual-use technologies.
• Carries out any act required under UN Security Council resolutions that aim to stop the spread and financing of weapons of mass destruction.

Knowledge of the crime can be understood from the facts and circumstances surrounding the situation.

Obligations for Entities:

• Financial institutions and DNFBPs (which include real estate agents, accountants, lawyers, and precious metal dealers), VASPs, and non-profit organisations have to perform CDD procedures. They need to continue customer monitoring while it performs risk assessments, maintains its records and sends suspicious transaction reports to the Financial Intelligence Unit (FIU) without delay.
• Beneficial ownership rules must be followed strictly. Anonymous accounts are not allowed, and all entities must fully follow targeted financial sanctions.
• All entities must have internal controls. They must provide training programs and use risk‑based methods in their work.

Penalties Under Financial Crime Law

Implementing Regulation: The Cabinet Resolution No. 134 of 2025 establishes specific procedures which must be followed together with customer due diligence requirements, problem reporting methods and penalty assessment procedures. The Central Bank regulates financial institutions while the Ministry of Economy manages supervision of DNFBPs.

2. Federal Decree-Law No. 31 of 2021 Promulgating the Crimes and Penalties Law (UAE Penal Code)

This is the main criminal law (updated version) that covers general financial crimes not fully covered by the AML Law. It works together with the AML Law.

It also makes companies responsible for crimes (Article 66). If a director, manager, or employee commits a crime on behalf of the company, then the company can also be punished.

The main provision relating to crime includes:

• Bribery and corruption (Articles 275 to 287)

These laws punish anyone in the public or private sector who asks for, accepts, offers, or gives a gift or benefit they should not receive in return for doing something or not doing something in their job. 

They apply to public servants, foreign officials, international‑organisation employees, and private‑sector managers.

Penalties include imprisonment, fines up to the total amount of the bribe, and confiscation of the gift. Even those who abet or facilitate bribery are liable to punishment. 

The briber or the intermediary shall be exempted from the penalty if he informs the judicial or administrative authorities of the crime before it is discovered.

• Fraud (Article 451): 

A person is punished with jail or a fine if they use fraud, a fake name, or a false identity to take someone else’s property, documents, or signatures, or to make someone hand them over. The same punishment applies if someone sells or uses property they know is not theirs, or if they already sold it before, and this causes harm to others.

If the property belongs to the State or a government authority, the punishment is more serious.

Penalty: Attempting the crime can lead to up to 2 years in jail or a fine up to AED 20,000. If the offender has done similar crimes before, the court may add probation for up to 2 years.

• Breaches of Trust  (Article 453): 

Any person who takes, uses, or misuse money or property (through a lease, loan, mortgage, or as an agent) that was given to them in trust and uses it in a way that harms the real owner shall be liable for breach of trust. Punishment for such crime includes imprisonment and/or fine.

Partners in shared property, agents acting out of necessity, and anyone given something to use for a specific purpose are treated the same as a trusted agent. 

Penalty: A person can be punished with up to two (2) years in jail or a fine of up to AED 20,000 if they knowingly take lost property belonging to someone else, or keep property they received by mistake or due to an unexpected event. 

The same penalty applies to anyone who embezzles property they previously mortgaged to secure a debt, or an owner who is made custodian of their own property under court or administrative attachment and then embezzles any part of it.

• Other offences include: Forging documents or money, stealing public money, and using influence illegally (influence peddling).

3. Federal Decree-Law No. 34 of 2021 On Countering Rumours and Cybercrimes

This law protects the UAE from cybercrimes. It stops people from misusing the internet, online platforms, and technology.

It aims to prevent hacking, tampering with government systems, spreading rumours or fake news, online fraud, and violations of privacy. The law makes it illegal to commit crimes using information technology, electronic systems, or the internet.

Main Financial Crime law provision include:

• Infringement of Data of Financial, Commercial or Economic Establishments (Article 8):

Anyone who, without permission, uses technology to take, copy, change, delete, leak, or share confidential data belonging to any financial, commercial, or economic business will face temporary imprisonment of at least five years and a fine between AED 500,000 and AED 3,000,000.

• Handling illegal money through technology (Article 30): 

Anyone who uses any information network or technology to move, transfer, hide, or use illegal funds — knowing they come from an unlawful source — can be punished with up to 10 years in jail and a fine between AED 100,000 and AED 5,000,000.

This includes transferring illegal funds to hide their source, hiding the truth about the funds, or using them while knowing they are illegal. The same punishment also applies to anyone who creates, runs, or manages a website, or shares information online to help or encourage others to commit these illegal acts.

• Online fraud or scams (Article 40): 

Anyone who uses any kind of fraud, fake name, or false identity through an online system to take someone else’s property, benefit, or document — or to make someone sign a document — will be punished with at least one year in jail and/or a fine between AED 250,000 and AED 1,000,000.

 In short, this law covers crimes such as:

• creating false data or robots to spread it, 
• falsifying electronic documents, 
• invading privacy, 
• tampering with medical or banking information, 
• e‑begging, 
• publishing content that breaks media rules, 
• creating or keeping illegal online content, 
• promoting human trafficking, 
• using or moving illegal funds, 
• raising money without a licence, 
• blackmail,
• insults, 
• unlicensed surveys or demonstrations, 
• offending religions or foreign countries, 
• promoting weapons, and 
• misleading consumers .

Regulatory Authorities and Enforcement

• Financial Intelligence Unit (FIU): The FIU functions as a unit that operates within the Central Bank. It gets reports about suspicious financial activities. The FIU verifies the report before sending it to the appropriate authorities.
• Ministry of Economy: The Ministry of Economy acts as a governmental body that regulates financial institutions which include all entities except banks. The financial institutions include lawyers, accountants, real estate agents and free trade zones. The organization makes sure that its members follow all money laundering laws.
• Supreme Committee and National Committee: It conducts research to assess financial risk. The committee creates money laundering policies and terrorist financing control policies. The organization works together with international partners to fight against money laundering and other financial crimes.
• Law Enforcement and Public Prosecution: The police and prosecution enforce the laws by prosecuting suspected offenders. They can block financial accounts, seize ill-gotten assets, and cooperate with other nations.

The enforcement is centered on the following key issues:

• Prioritizing high-risk financial sectors.
• Cooperating with international organizations
• Seizing criminal assets

Besides, the UAE participates actively in international programs such as the United Nations sanctions programs.

Compliance Considerations and Best Practices

Firms and corporations operating in UAE have to observe the following measures:

• Implement adequate internal control mechanisms and checks
• Conduct regular risk assessment
• People working with the firms should be trained adequately
• The firms should retain records for at least five years

Failure to comply with these regulations exposes the firms and corporations to severe consequences such as hefty fines, revocation of their license, or prosecution.

High-risk sectors (such as banking, real estate, virtual asset services like cryptocurrency trading, and precious metals and stones) require strict scrutiny. For the most recent and updated information, visit the following official websites:

• Regulations Portal in UAE (uaelegislation.gov.ae)
• MoE AML Website

• Central Bank AML/CFT resources

Disclaimer: This information is for general purposes only and does not create any client–attorney relationship. It should not be construed as legal advice. For guidance specific to your situation, please consult a qualified legal professional.

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