Federal Decree-Law No. 10 of 2025: Heightened AML, CFT & CPF Mandates for UAE DNFBPs

The Evolution from Decree-Law 20/2018 to Decree-Law 10/2025

The UAE Federal Government enacted Federal Decree-Law No. 10 of 2025 on Combatting Money Laundering, Financing of Terrorism, and Counter-Proliferation Financing, completely repealing and replacing Federal Decree-Law No. 20 of 2018.

While the core risk-based foundation remains intact, Decree-Law 10 of 2025 significantly broadens the statutory responsibilities of Designated Non-Financial Businesses and Professions (DNFBPs). Specifically, it elevates Counter-Proliferation Financing (CPF)—preventing illicit state and non-state actors from acquiring weapons of mass destruction and sensitive dual-use technology—into a primary statutory obligation alongside traditional anti-money laundering controls.

Under Cabinet Resolution No. 134 of 2025 (the Executive Regulations), commercial organizations falling under the DNFBP definition must update their institutional risk assessment frameworks to incorporate explicit proliferation financing risk indices.

Beneficial Ownership Updates: The 15-Working-Day Rule (Article 38)

A critical compliance update for corporate secretariats and compliance officers concerns the reporting of beneficial ownership changes:

Under Article 38 of Cabinet Resolution No. 134 of 2025, legal persons must notify the licensing authority or competent registrar of any change or amendment to beneficial ownership information within strictly 15 WORKING DAYS from the occurrence of the change.

Distinguishing the Regulatory Layers: Earlier corporate transparency rules under Cabinet Resolution No. 109 of 2023 on the Regulation of Real Beneficiary Procedures established basic UBO register filing duties for commercial entities. The new Executive Regulations under Cabinet Resolution No. 134 of 2025 explicitly codify the 15-working-day statutory timeline within the federal AML/CFT/CPF enforcement regime, empowering supervisory authorities to levy administrative penalties for delayed filings.

Corporate entities must ensure that any share transfer, nominee arrangement, or restructuring of controlling interests is reflected in the official register within this 15-working-day window.

Core Operational Adjustments for UAE Commercial Entities

Compliance officers and company directors must address four immediate operational requirements mandated by the updated legislation:

1. Real-Time Sanctions & CPF Screening: Entities must screen all customer counterparties, ultimate beneficial owners, and directors against the UAE Local Terrorist List and UN Security Council Consolidated Lists prior to onboarding and upon any list update. Automated daily screening is now standard practice.

2. Timely 15-Working-Day UBO Notifications: Maintaining up-to-date Registers of Beneficial Owners, Nominee Directors, and Partners, submitting changes within the statutory 15 working days.

3. Enhanced Suspicious Transaction Reporting (STR / SAR): Filing timely reports on the FIU goAML portal when suspicion arises regarding transactions, funds, or attempted deals, adhering strictly to anti-tipping-off rules.

4. Independent AML Testing Function: DNFBPs are statutorily required to maintain an independent audit function to periodically test and verify internal controls, separate from the designated compliance officer.

Supervisory Inspections and Enforcement Measures

The Ministry of Economy and Free Zone regulatory authorities maintain active on-site and remote supervisory inspections across Abu Dhabi and Dubai. Inspectors focus heavily on:

Examining whether the entity has an approved AML Policy Manual tailored to its specific business activities, rather than an off-the-shelf template.

Reviewing documented Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD) files for Politically Exposed Persons (PEPs).

Inspecting staff training logs to verify that resident employees receive verified annual AML/CFT/CPF training.

Integrity Chartered Auditors provides independent AML compliance testing, gap assessments, and outsourced review services to ensure total alignment with Federal Decree-Law No. 10 of 2025 and Cabinet Resolution No. 134 of 2025.