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United Arab Emirates (AE) · Module Detail

United Arab Emirates: AML/CFT & Financial Crime (Sentinel.gi-fed)

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Post-FATF-grey-list CBUAE AML enforcement campaign (AED 370m+ fines, license revocations, personal MLRO sanctions); PSP/SVF full AML obligations under FDL No.20 of 2018 as amended (No.7 of 2024, No.10 of 2025). Sentinel-fed; original analysis routed to FIM.

Standing sub-brief · as of 7 July 202691 words · last cycle 2026-08-05

AML/CFT & Financial Crime

This module is sourced from the Sentinel feed: since the start of 2025 CBUAE has levied AML/CFT fines exceeding AED 370 million (over US$100 million) across foreign bank branches, exchange houses, insurers and brokerages, including licence revocations and personal sanctions on compliance officers and MLROs, grounded in Federal Decree-Law No. 20 of 2018 as amended by No. 7 of 2024 and No. 10 of 2025.

Periodic update · new data 2026-08-11

AML/CFT & Financial Crime

This module carries Sentinel-fed intelligence per standing methodology; original illicit-finance analysis is not performed here. Sentinel identifies two linked developments this cycle. First, Federal Decree-Law No. 10 of 2025, effective 14 October 2025, replaces the UAE's core AML/CFT/CPF statute and expands scope to payment-sector reporting entities and virtual-asset service providers. Second, the Central Bank of the UAE imposed a AED20 million institutional fine plus a AED300,000 personal fine against the branch's Money Laundering Reporting Officer on 24 June 2026, for repeated AML/CFT and sanctions-framework failures.

Readers should treat these as attributed Sentinel-feed signals rather than as this brief's own illicit-finance assessment; for typology-level analysis of the UAE's AML/CFT exposure, including beneficial-ownership and sanctions-evasion architecture, consult FIM's dedicated coverage.

Outlook

The marker to watch, per the Sentinel feed, is whether further CBUAE enforcement actions follow the pattern of this cycle's institutional-plus-personal fine structure, and whether the new statute's expanded VASP and payment-sector scope generates additional reportable enforcement activity in coming cycles.

Sources and findings (6)
  1. T1https://rulebook.centralbank.ae/en/rulebook/guidance-licensed-financial-institutions-risks-relating-paymentsretrieved
  2. T?FIM (sentinel.gi) per-JID baseline profile — United Arab Emirates — UAE operates under Federal Decree-Law No. 20 of 2018 (as amended) on AML/CFT, a federal FIU (goAML-based), and a layered crypto regime (CBUAE, SCA, VARA, DFSA, FSRA). Delisted from FATF grey list (Feb 2024) and EU high-risk AML list (Jun 2025) after action-plan remediation, but fragmented free-zone supervision (7 emirates, 2 financial free zones, ~39 commercial free zones/registries) and weak BO transparency persist structurally.
  3. T?FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-004) — Gap: sourcing-thinness
  4. T3FIM (sentinel.gi) sanctions_change_register (issue FIM-BASE-SANC-003) — Sanctions: EU divergence
  5. T?FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-001) — Gap: regulatory-failure
  6. T?FIM (sentinel.gi) gaps_register_cumulative (issue FIM-BASE-GAP-003) — Gap: enforcement-absence