UAE AML Framework Update: Cabinet Decision No. 134 of 2025

The UAE has entered a new phase in its anti-money laundering and counter-terrorist financing regime with the issuance of Cabinet Decision No. 134 of 2025. This landmark decision introduces the Executive Regulations to Federal Decree-Law No. 10 of 2025, setting out a more structured, enforceable, and risk-focused AML framework across the UAE.

At its core, AML Law No. 10 of 2025 replaces the earlier 2018 regime and formally expands the scope of financial crime to include money laundering, terrorist financing, and the financing of the proliferation of weapons. Cabinet Decision No. 134 of 2025 operationalises this law, replacing Cabinet Decision No. 10 of 2019 and translating legislative intent into practical compliance obligations.

Key regulatory changes include the explicit inclusion of proliferation financing within the risk-based approach, expanded coverage of Designated Non-Financial Businesses and Professions (DNFBPs), and the full integration of Virtual Asset Service Providers (VASPs) into the UAE AML framework. VASPs are now subject to customer due diligence, transaction monitoring, sanctions screening, and suspicious transaction reporting obligations comparable to traditional financial institutions.

The Executive Regulations also significantly enhance customer due diligence and Ultimate Beneficial Ownership (UBO) transparency requirements. Businesses must now update UBO information within strict timelines, prohibit bearer shares, disclose nominee arrangements, and strengthen verification processes. Enhanced Due Diligence expectations have been clarified, including mandatory source of wealth analysis and senior management approval for higher-risk relationships.

Cabinet Decision No. 134 of 2025 further strengthens the powers of the UAE Financial Intelligence Unit (FIU), enabling faster suspensions, temporary asset freezes, broader access to information, and enhanced international cooperation. As a result, businesses should expect increased supervisory engagement and tighter response timelines.

With the Executive Regulations now in force, all Financial Institutions, DNFBPs, and VASPs should conduct immediate AML gap assessments, update internal policies, and ensure readiness for enhanced regulatory scrutiny.

At Darj, we assist businesses across the UAE with AML compliance advisory, regulatory gap assessments, DNFBP and VASP compliance support, and ongoing AML governance. Our approach is practical, regulator-aligned, and designed to help businesses meet their obligations under Cabinet Decision No. 134 of 2025 with confidence.