The UAE Anti-Money Laundering Landscape – More Enforcement to Come?

Key Points:

• The UAE has set out its clear commitment to preventing money laundering, following its removal from the FATF grey list in February 2024 and the EU list of high-risk third countries in August 2025.
• In October 2025, the UAE introduced a significant new federal law on anti-money laundering, financing of terrorism and proliferation financing which significantly strengthens the legislative framework—introducing personal liability for managers, lowering the knowledge threshold for offences and widening the ambit of the anti-money laundering regulatory regime to capture virtual asset service providers.
• Enforcement efforts have ramped up from the UAE Central Bank, as well as freezone regulators such as the FSRA, while the DFSA has signalled its commitment through expanded recruitment (looking towards the U.K. and Hong Kong) and investment in resources.

Introduction

In early September 2025, the U.K. and UAE Governments conducted talks in London “to strengthen bilateral co-operation in the fight against illicit finance,” including anti-money laundering (AML) and counter terrorist finance (CTF) measures.¹ Since the UAE’s removal from the Financial Action Task Force’s (FATF) grey list in February 2024,² and almost 18 months later on August 5, 2025, having been taken off the European Union’s (EU) list of “high-risk third countries” for AML purposes,³ the UAE is keen to cement itself as a “safe” jurisdiction for AML and CTF matters, and has continued to make strides in the AML sphere.

New AML Federal Law

On September 30, 2025, the UAE’s Federal Decree – Law No. 10 of 2025, Concerning Combating Money Laundering, Terrorism Financing and the Financing of Proliferation was issued,⁴ effectively rehauling the UAE’s prior AML framework (Federal Law No. 20 of 2018). The key changes introduced through this new legislation include:

• Proliferation Financing – The prior AML framework did not cover proliferation financing (i.e., financing to support parties to develop or obtain weapons of mass destruction), but the new framework expressly includes proliferation financing as an offence, in line with money laundering and terrorist financing.
• Digital Assets – The new framework specifically references the use of digital systems, virtual assets or cryptographic technologies in the commission of money laundering and terrorist financing offences. It also explicitly includes virtual asset service providers as being subject to the UAE’s AML regime.
• Knowledge – The threshold for establishing offences has been lowered, such that a person can be liable where they have actual knowledge or it would have been reasonable for them to have known (i.e., an objective test, not just subjective).
• Penalties – Penalties have significantly increased from AED 500,000—50 million to AED 5 million—100 million for legal entities; and from AED 5 million to AED 10 million for regulated entities. Administrative penalties can also be imposed, including fines of up to AED 5 million, suspension of business activities, revocation of licenses and removal of senior management. Courts can also now order the dissolution of a legal entity or closure of its headquarters if convicted of money laundering.
• Limitation Period - No limitation period applies to offences, meaning that the risk of liability remains indefinitely.
• Senior Management – Senior management is responsible for approving internal policies, procedures and controls to mitigate identified risks and updating them regularly. Senior management is defined broadly as “the person or persons vested with authority to take strategic and executive decisions materially affecting risk management, compliance policies, and operational governance, including… any person occupying a position that enables them to directly influence the conduct of business and internal policies, including compliance policies.” In addition, managers of legal entities can now face personal criminal liability if they have actual knowledge of an offence, or if the offence occurred as a result of a breach of their duties.
• Enforcement Powers – Enforcement powers have been expanded so that the Financial Intelligence Unit can now issue seizure and freezing orders; previously only the UAE Central Bank and Public Prosecutor could do so. In addition, courts in the UAE are authorized to enforce foreign judicial orders, without separate investigation.

UAE Enforcement

Enforcement in the UAE both onshore and in the freezones ramped up during 2025. The UAE Central Bank has continued to aggressively pursue enforcement, issuing over AED 370 million in fines in 2025, in addition to license cancellations and suspensions. In particular, in May 2025 it imposed: (i) an AED 18.1 million fine on two branches of foreign banks operating in the UAE for failures to comply with the AML regime;⁵ and (ii) an AED 200 million fine on an exchange house for significant failures in the exchange house’s AML and CTF framework.⁶

Dubai Financial Services Authority

The Dubai Financial Services Authority’s (DFSA) remit is growing, and rapidly. During 2024, the number of authorised firms increased by 14% year-on-year, with more than 900 firms now subject to the DFSA’s jurisdiction,⁷ driven by a 75% increase in the number of wealth management licences.⁸ This is getting close to double the 502 firms which were authorised by the end of 2019.⁹

With this growth, it is unsurprising that the DFSA has made several new, and experienced, hires. Given the similarities between the DFSA’s Rulebook and the U.K. Financial Conduct Authority’s (FCA) Handbook—not least the “Principles” underlying each regulatory system¹⁰ it is unsurprising that the DFSA looked to the FCA when headhunting.

The New Hires

In the last few years, the DFSA and the Dubai regulatory system have made several significant hires.

In October 2023, Judge Herrington was appointed as President of the Dubai Financial Markets Tribunal (the Tribunal). He was previously the senior financial services judge in the U.K. Upper Tribunal, the primary judicial forum for challenges to regulatory decisions by the FCA. Judge Herrington had also previously been the Chair of the FCA’s Regulatory Decisions Committee, a quasi-autonomous committee of the FCA board which is required to approve significant enforcement and supervisory decisions.

In March 2024, Javan Herberg KC was appointed to the board of the DFSA. Mr. Herberg KC is one of the most well known “silks” at the English bar in financial services law, acting both for and against the FCA.

In May 2025, Mark Steward was appointed Chief Executive of the DFSA. Mr. Steward was previously the Executive Director of Enforcement and Market Oversight at the FCA, and prior to that an Executive Director of Enforcement at Hong Kong’s Securities and Futures Commission (SFC).

Finally, in July 2025, Alan Linning was appointed Managing Director, Enforcement of the DFSA. Mr. Linning was previously the Executive Director of Enforcement at Hong Kong’s SFC.

What’s Next for the DFSA and Enforcement?

Currently, the number of publicised enforcement cases remains relatively low. In 2024, the DFSA received 670 complaints (an increase of 23% over the previous year), and opened 12 matters for investigation, and 8 Enforcement actions were completed, being 5 against firms and 3 against individuals.¹¹ Over $2 million in fines were issued, including one fine to an individual of some $980,000. Whilst still nothing like the level of fines in the US or even the U.K., these are not trivial amounts, particularly when levied on an individual.

It should be recalled, however, that in certain circumstances, the DFSA has not been shy about issuing very large fines. Notably, in 2019, fines totalling approximately $315 million were imposed on companies related to Abraaj Investment Management Limited.

2025 was, at least from an external view, quiet for DFSA enforcement, with only one public enforcement outcome published. This was against Mr. Kulvir Virk, who was prohibited from performing any financial services activity in the Dubai International Financial Centre (DIFC).¹² This followed a prohibition order made by the FCA against Mr. Virk, finding that he had failed to act with integrity in relation to an FCA authorised firm. While Mr. Virk had been acting for an FCA authorised firm, he was living and working in Dubai, and was associated with a DIFC firm, such that while he was not formally employed by that firm, he was involved in that firm’s decision making. Leaning on the FCA’s findings, the DFSA imposed a restriction on Mr. Virk.

2026 has already had more outcomes announced than 2025. The DFSA has announced the issuance of a fine of $455,176 (after applying a 30% settlement discount)¹³ on reinsurance brokerage, Ed Broking (MENA) Limited, for engaging in misleading and deceptive conduct.¹⁴ In a second decision, the DFSA has also imposed a $504,000 fine on Ark Capital Management (Dubai) Limited (after applying a 30% settlement discount) for (i) failure to notify the regulator of transactions by the firm’s clients for which it had reasonable grounds to suspect may have constituted market abuse, and (ii) failure to notify the DFSA of a change in its controllers.

The Financial Markets Tribunal has also recently announced its upholding of a $25,000 fine on Al Ramz Capital LLC, in the first substantive decision given by Judge Herrington.¹⁵ In doing so, the Tribunal upheld the DFSA’s decision to fine Al Ramz for a similar failing to Ark Capital, namely failing to report suspicious transactions by notifying the regulator when it had reasonable grounds to suspect that one of Al Ramz’s clients was engaging in market abuse.

Abu Dhabi Financial Services Regulatory Authority

ADGM’s regulatory authority, the Abu Dhabi Financial Services Regulatory Authority (FSRA), has also recently been busy, pursuing 16 enforcement actions, including a $8.85 million fine on the HAYVN group of entities (see more below), and four penalties relating to contraventions of AML requirements.¹⁶

In August 2025, the FSRA issued a $20,400 penalty (after a 20% settlement discount)¹⁷ on UHY James Chartered Accountants¹⁸ for a failure to implement adequate AML policies and procedures, implement and maintain effective systems and controls to screen customers, conduct a business risk assessment, undertake customer risk assessments and adequately perform customer due diligence.

In November 2025, the FSRA issued a $51,000 penalty (after a 20% discount) on FWS Group Ltd.,¹⁹ for a failure to implement adequate AML policies and procedures, conduct a business risk assessment, adequately undertake a customer risk assessment, adequately perform customer due diligence and ongoing customer due diligence and appoint a new MLRO on a timely basis.

While the above penalties focusing on AML are relatively low-value, they demonstrate the willingness of the FSRA to take action, regardless of the size of the penalty, as it seeks to impose a “zero-tolerance” approach to breaches.

In addition, the increasing focus on digital systems and virtual assets is clearly demonstrated by the significant $8.85 million fine imposed on the HAYVN Group and its former CEO, Christopher Flinos, in April 2025.²⁰ The HAYVN group is a group of entities that provided financial services related to virtual assets. The breaches related (amongst others) to a failure to establish and maintain adequate systems and controls (breaching FSRA AML requirements), conducting unlicensed activities relating to virtual assets in ADGM and providing false and misleading information to the FSRA in response to requests for information.

Next Steps

As the next FATF Mutual Evaluation approaches in June 2026, it is evident that the UAE is focusing on a “zero-tolerance” approach across its regulators towards money laundering. At the 22nd Meeting of the Higher Committee Overseeing the National Strategy on Anti-Money Laundering and Countering the Financing of Terrorism, the UAE’s ongoing commitment to strengthening its AML/CTF framework was reinforced, with the approval of a national proliferation financing risk assessment, as well as a mechanism to update national risk assessments for AML/CTF every three years.²¹

Remarks made by Futoon Al Jassim, Head of Sanctions Implementation Compliance at the Executive Office for Control and Non-Proliferation at the recent Global Investigations Review (GIR) Live Annual Investigations MENA Conference in Dubai included that combating financial crime is considered “a national priority” for the UAE.²² Mark Steward also gave the keynote speech²³ at the same conference, reiterating that financial crime is a “practical and present priority” and that “we are diligently preparing for the upcoming UAE FATF Mutual Evaluation this year… working closely with the UAE federal authorities, the FIU and the Executive Office for Control and Non-Proliferation (EOCN) to support on the UAE’s National Risk Assessment and enhance the country’s AML/CTF framework.”

We expect enforcement to increase throughout 2026, particularly in light of the updates to the AML framework including reduced knowledge requirements and no limitation period. In addition, there is an increased focus on digital systems and virtual assets, as seen by the expansion of the AML framework to cover virtual asset service providers, recent updates to the DFSA Rulebook and the FSRA’s significant enforcement action against HAYVN group. Firms should consider conducting the following:

• Review of Policies and Procedures - To reflect the latest updates introduced by the new legislation, in particular ensuring that there are adequate controls in place to address proliferation financing, and risks posed by digital systems and virtual assets.
• Refreshed Training - To highlight to individuals the new personal liability exposure, and lower knowledge requirements.
• Senior Management Briefings - Boards and senior management should be briefed on the changes to the penalties framework, and risks for senior management in particular.
• Updated Risk Assessment – Risk assessments, particularly regarding third-party engagement and reporting of suspicious transactions, should be carried out in light of the increased enforcement environment and changes in law.

^{1 https://www.gov.uk/government/publications/uae-and-uk-conclude-bilateral-visit-to-strengthen-partnership-against-illicit-finance.}

^{2 https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/Increased-monitoring-february-2024.html.}

^{3 https://eur-lex.europa.eu/eli/reg_del/2025/1184/oj/eng.}

^{4 https://uaelegislation.gov.ae/en/legislations/3314/download; as implemented by Cabinet Executive Regulation No. 134 of 2025 (https://uaelegislation.gov.ae/en/legislations/3857/download).}

^{5 https://www.centralbank.ae/media/tmddneqk/cbuae-imposes-financial-sanctions-of-aed-18-1-million-on-two-branches-of-foreign-banks-en.pdf}

^{6 https://www.centralbank.ae/media/u1yfjiyi/cbuae-imposes-a-financial-sanction-of-aed-200-million-on-an-exchange-house-en.pdf}

^{7 https://www.dfsa.ae/news/dfsa-annual-report-2024-published-year-marking-key-regulatory-developments-continuous-supervisory-activity-and-strengthened-stak}

^{8 https://www.dfsa.ae/news/dfsa-annual-report-2024-published-year-marking-key-regulatory-developments-continuous-supervisory-activity-and-strengthened-stak.}

^{9 https://365343652932-web-server-storage.s3.eu-west-2.amazonaws.com/files/3816/0334/0773/DFSA_Annual-Report_2019-ENG-Final-1-Oct-2020.pdf.}

^{10 In PRIN 2.1 (here) for the FCA and in GEN 4 (here) for the DFSA.}

^{11 https://365343652932-web-server-storage.s3.eu-west-2.amazonaws.com/files/2917/4634/8102/DFSA_2024_Annual_Report_-_English.pdf.}

^{12 https://365343652932-web-server-storage.s3.eu-west-2.amazonaws.com/files/9717/6526/0365/Decision_Notice_K_Virk_Redacted.pdf.}

^{13 Under DFSA Regulatory Policy and Process Sourcebook 6-8-2, the DFSA may offer the offending company/individual an opportunity to settle (i.e, reach an agreement with the DFSA on the content of any notice, the sanction and the findings of the DFSA). In most cases, the DFSA will specify a time period of 28 days in order to reach agreement with the DFSA. If settlement is reached within this 28-day period, or such other period allowed by the DFSA, a 30% discount may be applied to the amount of the financial penalty.}

^{14 https://365343652932-web-server-storage.s3.eu-west-2.amazonaws.com/files/3017/7001/3823/Ed_Broking_Decision_Notice_Signed_Redacted.pdf}

^{15 https://365343652932-web-server-storage.s3.eu-west-2.amazonaws.com/files/3517/7070/8939/AL_Ramz_decision.pdf.}

^{16 https://www.adgm.com/operating-in-adgm/additional-obligations-of-financial-services-entities/enforcement/regulatory-actions}

^{17 Under FSRA Guidance & Policies Manual 7.15, the FSRA may offer the offending company/individual an opportunity to settle. If a settlement is agreed, a 20% discount may be applied to the amount of the financial penalty.}

^{18 https://assets.adgm.com/download/assets/Final+Notice+RE+UHY+James+20250826.pdf/f0d65c1c83e011f0a5f69e2739edbdb2}

^{19 https://assets.adgm.com/download/assets/FSRA+Final+Notice+FWS+Group+Ltd.pdf/7833d1d6cac111f09d442aaa8facbbfe}

^{20 https://www.adgm.com/media/announcements/adgms-fsra-imposes-fines-of-USD-8-85-million-on-hayvn}

^{21 https://www.mofa.gov.ae/en/MediaHub/News/2026/2/12/bin-Zayed-UAE}

^{22 https://globalinvestigationsreview.com/just-sanctions/article/uae-export-control-official-highlights-countrys-priorities-threats-and-strides}

^{23 https://365343652932-web-server-storage.s3.eu-west-2.amazonaws.com/files/6617/7149/0183/Global_Investigations_Review_Speech_CE_MarkSteward_Feb_2026.pdf}