AML Compliance for UAE Businesses: a Comprehensive Guide to Federal Law No. 10 of 2025
The law's risk-based approach starts with your own exposure, then the controls, people and audits that follow
Federal Law No. 10 of 2025 requires businesses to take a risk-based, proactive approach to AML compliance. This article covers the risk assessment that comes first, the controls it leads to, and the compliance officer, staff training and independent auditing that support them.
Reviewed by Mohamed Noureldin, Founder, Managing Partner & Senior Legal Consultant
Federal Law No. 10 of 2025, the UAE's new Anti-Money Laundering (AML) law, represents the most significant overhaul of the country's financial crime framework in years. Its approach is risk-based and proactive, so the starting point is your own business: the money laundering and terrorism financing risks it is exposed to, and whether your policies, procedures and controls mitigate them.
Why the programme has to stay current
Money laundering and terrorism financing are complex and constantly evolving threats. Criminals are always looking for new ways to exploit the financial system to launder the proceeds of their crimes.
Businesses need to stay constantly vigilant, and to keep an up-to-date AML compliance programme in place.
Your own risks come first
The new AML law requires businesses to take a risk-based and proactive approach to AML compliance. This means identifying and assessing their own specific money laundering and terrorism financing risks, and implementing policies, procedures and controls to mitigate them.
An effective AML compliance programme should include the following key components: a risk assessment; policies, procedures and controls; a designated compliance officer; regular employee training; and independent auditing.
Mapping exposure before writing controls
The first step in building an effective AML compliance programme is to conduct a full risk assessment. This should identify the specific money laundering and terrorism financing risks that your business is exposed to.
The risk assessment should take into account a range of factors, including:
- the nature of your business and its products and services
- the geographic locations in which you operate
- the types of customers you deal with
- the delivery channels you use
Controls that answer the risks found
Once you have identified your risks, you need to implement AML compliance policies, procedures and controls to mitigate those risks. These should include:
- Customer due diligence (CDD). You need to have a clear process for identifying and verifying the identity of your customers. This should include conducting enhanced due diligence on high-risk customers.
- Transaction monitoring. You need to have a system in place for monitoring customer transactions to identify any suspicious activity.
- Record keeping. You need to keep detailed records of all customer due diligence and transaction monitoring activities.
- Reporting suspicious transactions. You need to have a clear process for reporting any suspicious transactions to the UAE's Financial Intelligence Unit (FIU).
Oversight and training inside the business
You need to appoint a designated compliance officer who is responsible for overseeing your AML compliance programme. The compliance officer should be a senior employee with the necessary skills and experience to perform this role effectively.
All employees who are involved in customer-facing or transaction-processing roles need to receive regular training on your AML policies and procedures. The training helps ensure they are aware of their obligations, and that they know how to identify and report suspicious activity.
Independent audit, and more than a box to tick
Your AML compliance programme should be subject to regular independent auditing. The audit is there to ensure that the programme is effective and that it is being implemented correctly.
Compliance with the new AML law is not just about ticking a box; it is about creating a culture of compliance within your organisation. This means that all employees, from the most senior to the most junior, need to understand the importance of AML compliance, and need to be committed to playing their part in protecting your business from financial crime.
Building an effective AML compliance programme can be a complex and challenging task, and the experienced specialists in our AML compliance practice can provide expert advice and support.
Disclaimer: The information provided in this article is for general informational purposes only and does not constitute legal advice. Readers should seek professional legal advice tailored to their specific circumstances before making any decisions or taking any action based on the content of this article.
