Anti-money laundering compliance in the UAE has entered a new era. With Federal Decree-Law No. 10 of 2025 now fully in force, businesses across the country face a stricter, better-resourced, and far less forgiving enforcement environment than they did even two years ago. For companies still operating on the assumption that AML is a “banking problem,” 2026 is the year that assumption becomes an expensive mistake.

At RH & HALE, our regulatory and compliance teams work with financial institutions, real estate firms, corporate service providers, and other regulated businesses across Dubai and Abu Dhabi to help them understand exactly what the law requires and what happens when it isn’t followed. Here is what every UAE business needs to know about AML non-compliance penalties in the UAE in 2026.

A New Law, A Tougher Framework

On 14 October 2025, Federal Decree-Law No. 10 of 2025 concerning Anti-Money Laundering, Combating the Financing of Terrorism, and Combating the Financing of Proliferation came into effect, repealing and replacing the previous Federal Decree-Law No. 20 of 2018. This was not a minor update. The new law rebuilds the UAE’s AML/CFT framework from the ground up, introducing an entirely new category of offence, tightening beneficial ownership rules, and significantly raising the ceiling on corporate fines.

The timing is deliberate. The UAE was removed from the Financial Action Task Force’s “grey list” of jurisdictions under increased monitoring in early 2024, and from the European Union’s list of high-risk third countries in mid-2025. Both exits followed sustained reform and aggressive enforcement, and UAE regulators have made clear they intend to maintain that trajectory rather than ease off now that international scrutiny has lifted.

Administrative Penalties: What a Business Can Be Fined

Administrative fines under the current regime typically range from AED 50,000 to AED 5,000,000 per violation, with repeat or aggravated violations attracting significantly steeper penalties. Regulators — including the Central Bank of the UAE, the Ministry of Justice, and the relevant free zone authorities — are also empowered to:

• Suspend or restrict a company’s business activities
• Revoke trade licences
• Remove board members or senior executives found responsible for violations
• Impose aggregate corporate fines that can now reach AED 100 million, up from the previous cap of AED 50 million

Designated Non-Financial Businesses and Professions, commonly known as DNFBPs, remain squarely within scope. This category includes real estate brokers and developers, dealers in precious metals and stones, corporate service providers, auditors, accountants, and law firms. Any business that falls into these categories and has not registered on the goAML platform, appointed a compliance officer, or implemented risk-based customer due diligence is already exposed.

Criminal Liability: Beyond the Balance Sheet

The 2025 law goes further than fines. It establishes independent corporate criminal liability, meaning a company and its individual managers or directors can each be prosecuted separately and simultaneously for the same underlying conduct. Personal liability can arise from deliberate misconduct, gross negligence, or wilful blindness — in other words, failing to investigate obvious red flags is treated as culpable in itself.

For individuals, this can mean imprisonment in addition to personal fines that sit apart from any penalty imposed on the company. Directors and compliance officers can also be disqualified from holding management positions. This marks a clear shift away from treating AML failures as a purely corporate cost of doing business, and toward holding named individuals personally accountable.

New: Proliferation Financing as a Standalone Offence

One of the most significant additions in the 2025 law is the introduction of proliferation financing as a distinct criminal offence — something that did not exist under the 2018 framework. This provision criminalises the provision of funds intended to support the development of weapons of mass destruction, including nuclear, biological, chemical, or radiological weapons. Penalties for this offence include temporary imprisonment alongside fines that can range from AED 1 million to AED 10 million, or double the value of the funds involved, whichever is higher.

Beneficial Ownership: A Recurring Enforcement Priority

Beneficial ownership transparency continues to be one of the areas regulators scrutinise most closely. Businesses are required to identify, verify, and maintain accurate records of their ultimate beneficial owners. Providing incorrect or misleading beneficial ownership information is a specific offence under the new law, carrying both imprisonment and a fine of no less than AED 20,000. Failing to maintain an accurate beneficial ownership register at all is separately penalised, regardless of intent.

Asset Freezing and No Statute of Limitations

Two further changes deserve particular attention from business owners and their advisors:

Extended freezing powers. The Financial Intelligence Unit can now freeze assets without a court order for up to ten working days, giving authorities a fast-acting tool to secure funds while an investigation proceeds. Permanent confiscation can follow by court judgment.

No limitation period. Offences under the new law are not subject to a statute of limitations. This means liability for AML violations does not expire with time, and historical failures can be pursued regardless of how long ago they occurred.

Enforcement Is Already Ramping Up

This is not a theoretical framework sitting untested. In one recent enforcement action, the Central Bank of the UAE fined a foreign bank branch operating in the country AED 20 million for repeated anti-money laundering and sanctions control failures, and separately fined the branch’s head of compliance personally for failing to fulfil the responsibilities of the money laundering reporting officer role. Regulators described the underlying failures as having been previously flagged and not durably remediated — a reminder that inspection findings which are acknowledged but not fixed can escalate quickly into formal penalties.

This pattern of pairing institutional fines with personal accountability for named compliance officers is becoming a defining feature of UAE enforcement, and it is unlikely to reverse.

What This Means for Your Business

If your AML programme still references the 2018 law, it is out of date, and quite possibly non-compliant with current obligations. Businesses operating in the UAE, particularly those in the DNFBP categories, should treat 2026 as the year to:

• Confirm registration on the goAML platform is current and accurate
• Review and, where necessary, rebuild customer due diligence and enhanced due diligence procedures for politically exposed persons
• Verify that beneficial ownership registers are complete, accurate, and regularly updated
• Reassess risk assessments and transaction monitoring to explicitly address proliferation financing risk
• Ensure compliance officers and MLROs understand their personal exposure under the new law, not just the company’s

How RH & HALE Can Help

Navigating a regulatory framework of this scope requires more than a compliance checklist. Our financial crime lawyers work alongside our corporate lawyers to advise regulated entities across the UAE on structuring AML programmes that meet current legal requirements, responding to regulatory inspections, and managing exposure when a compliance gap has already been identified. If your business needs to assess where it stands under Federal Decree-Law No. 10 of 2025, RH & HALE is here to help you get ahead of it before a regulator does.

This article is for general informational purposes and does not constitute legal advice. For guidance specific to your business, please consult with a qualified legal advisor.