Federal Decree-Law No. 10 of 2025 expanded how knowledge in money-laundering cases may be established, while its executive regulations placed clearer responsibilities on senior management. A June penalty against a bank compliance chief demonstrated the growing focus on individual accountability.
On 24 June 2026, the Central Bank of the UAE fined a branch of a foreign bank AED 20 million for what it described as significant, repeated failures in its anti-money laundering, counter-terrorist financing and sanctions framework. The same enforcement notice carried a second penalty: AED 300,000 imposed personally on the branch’s head of compliance and money laundering reporting officer, for failing to fulfil the responsibilities of his position.
Both were regulatory sanctions imposed under the Central Bank’s own legislation, not criminal convictions under the new AML law. The penalties are consistent with the wider shift towards institutional and individual accountability reflected in the UAE’s new AML framework: the new law creates criminal exposure for the person responsible for actual management where awareness and breach of duty are proved, while the regulations impose senior-management approval and oversight requirements.
It is a shift practitioners have been watching closely. Emirati advocate Fatima Hussein, founder of Fatima Hussein Law Firm and a lawyer with more than fifteen years of experience before UAE courts and the Public Prosecution, practises in precisely this territory; her firm describes its work as spanning money laundering, white-collar crime and sanctions matters.
A rebuilt rulebook
Federal Decree-Law No. 10 of 2025, in force since 14 October 2025, replaced the 2018 AML law. Cabinet Resolution No. 134 of 2025, containing the executive regulations, took effect on 14 December 2025, and the Central Bank issued updated AML guidance in April 2026. Legal persons convicted where their representatives, directors or agents committed money laundering, terrorist financing or proliferation financing on their behalf can face fines of up to AED 100 million, or the value of the criminal property involved if greater; Article 27 separately establishes potential criminal liability for the person responsible for actual management where awareness and breach of duty are proved. Proliferation financing is now a standalone offence carrying temporary imprisonment, which under the general penal framework can extend from three to 15 years unless another period is specified, and a fine of AED 1 million to AED 10 million. The law separately penalises tipping off, while gross negligence can attract liability in relation to failures to meet suspicious-transaction reporting obligations.
The basis for establishing knowledge
The most consequential change concerns proof. Article 2 applies where a person knows, or where sufficient indications or evidence support the belief, that funds are proceeds of a predicate offence and intentionally carries out one of the listed laundering acts. It also retains the principle that no predicate-offence conviction is required and permits knowledge to be inferred from the factual and objective circumstances. Separately, Article 30 creates liability for certain dealings in funds where sufficient indications or evidence suggest an illegitimate source or concealed beneficial ownership. According to analysis published by Greenberg Traurig’s Dubai office, cases are increasingly built on circumstantial material: transaction patterns, inconsistencies in documentation, unexplained movements of funds and the use of layered structures.
For finance teams, the documentary record becomes central. Contracts, invoices, banking records and source-of-funds evidence can help answer inferences drawn from transaction patterns or unexplained movements of funds, and they serve that purpose best when assembled before anyone asks.
Stricter beneficial-ownership requirements
The regulations expressly define nominee shareholders and nominee directors and exclude them from beneficial-owner status, increasing the transparency required around the individuals who ultimately own or control a legal entity. Ownership information must meet three defined standards, adequate, accurate and up to date, and intentionally providing incorrect or misleading beneficial ownership information to any authority carries imprisonment, a fine of no less than AED 20,000, or both.
Defined responsibilities for senior management
The regulations define senior management as anyone with authority over strategic or executive decisions affecting risk management, compliance policy or operational governance, including chief executives, general managers and board members. AML policies must be approved at that level, and higher-risk business relationships require senior management sign-off.
Three layers of exposure should be kept distinct. The regulations impose supervisory responsibility for approving and overseeing controls; supervisors such as the Central Bank can pursue administrative enforcement against licensed institutions and their officers, as the June penalties show; and criminal liability for management is narrower, arising where the person responsible for actual management knew about the offence and it resulted from a breach of their duties. A failed control does not by itself make a director a defendant, but it opens the questions that follow: who approved the policies, who implemented them, who responded to identified risks. The Chief of the Financial Intelligence Unit may also suspend a suspicious transaction for up to ten working days and freeze suspected funds for up to 30 days, subject to possible extension by the Attorney General or a delegate.
Fatima Hussein’s background sits at the criminal end of that spectrum. According to her published profile, Hussein previously worked in Al Tamimi & Company’s white-collar crime and investigations team, was shortlisted for Litigator of the Year in 2022, and has handled extradition and Interpol Red Notice matters.
Variation in practice
According to analysis published by Greenberg Traurig’s Dubai office, some police and prosecution teams continue to look for a clearly established predicate offence, and complex cases generally still require a local expert report connecting the financial flows to the elements of the offence. Practitioners report that approaches can still vary between investigations, particularly in complex or cross-border matters. FATF’s published calendar lists June 2026 as the indicative period for the UAE’s on-site assessment, with possible plenary consideration in February 2027. The evaluation examines both technical compliance and the effectiveness of implementation, with increased emphasis on results in practice.
The wider enforcement record points the same way: an exchange house was fined AED 200 million and two bank branches AED 18.1 million in May 2025. The recent enforcement actions show that AML failures can create consequences for both institutions and the individuals responsible for compliance. For UAE boards and senior management, the practical issue is no longer only whether policies have been approved, but whether their implementation can be demonstrated through records, decisions and responses to identified risks.
