UAE Introduces a New AML/CTF Framework: Corporate Liability Thresholds Significantly Increased

The UAE has introduced a new Anti-Money Laundering and Counter-Terrorist Financing framework with the issuance of Federal Decree-Law No. 10 of 2025, repealing the previous AML/CTF regime. The reform marks a significant step in the UAE’s shift towards stricter enforcement and closer alignment with international compliance standards.

The new law strengthens supervisory powers, broadens the scope of offences, and substantially increases corporate liability, reinforcing the UAE’s position as a jurisdiction committed to robust financial crime prevention.

Key changes under the new AML/CTF law

The updated framework introduces several important developments with direct implications for businesses operating in or through the UAE:

• New offences related to proliferation financing and virtual assets, reflecting evolving global risk areas

• Lower evidentiary thresholds, allowing “knowledge” to be inferred from factual circumstances rather than requiring direct proof

• Expanded supervisory powers, including the ability to impose asset freezes for up to 30 days • Significantly increased corporate liability, with administrative fines for legal entities reaching up to AED 100 million

These changes signal a move towards more proactive enforcement and heightened expectations around internal controls, governance and risk management.

Why this matters for Swiss and European businesses

The reform is not limited to banks, fintech firms or regulated financial institutions. Any UAE-based company — including holding structures, joint ventures, service providers and family offices — is now exposed to higher regulatory and enforcement risk if its AML and governance framework is not aligned with the new law.

Businesses operating cross-border must ensure that internal policies, risk assessments, onboarding procedures and governance structures are fully updated.

Failure to do so may result not only in regulatory sanctions, but also operational disruption and reputational damage.

For Swiss and European businesses in particular, the new framework reinforces the need for consistency between UAE compliance obligations and Swiss/EU regulatory standards.

Supporting compliance and cross-border alignment

Experts from Swiss Group Legal support clients in assessing the impact of the new AML/CTF framework and implementing practical compliance solutions.

This includes reviewing and updating AML manuals, conducting risk assessments, enhancing onboarding procedures and ensuring governance structures are aligned with both UAE requirements and international best practices.

Among the specialists advising on these matters are Raffaele Delorenzi, Head of Compliance, and Michael Lane, Head of Legal, who bring extensive experience in regulatory compliance, corporate governance and cross-border advisory.

Looking ahead

With enforcement thresholds lowered and penalties increased, the new AML/CTF framework represents a clear shift in regulatory expectations in the UAE. Businesses operating in the region should treat compliance readiness as a priority, ensuring their internal frameworks are not only compliant on paper, but effective in practice.

Early assessment and timely updates will be critical to managing regulatory risk and maintaining operational resilience in an increasingly strict compliance environment.