The 2020 Mutual Evaluation exposed significant weaknesses in the UAE’s AML/CFT system, ultimately leading to grey listing. Since then, the UAE has enacted sweeping reforms. Federal Decree-Law No. 10/2025, which came into effect on 14 October 2025, repealed and replaced the 2018 AML law, introducing standalone offences for proliferation financing, expanding predicate offences to include tax evasion, and explicitly covering digital systems and virtual assets.

The UAE has also launched a national strategy for AML, CTF and proliferation financing for 2024 to 2027, developed on the basis of its third National Risk Assessment, published in April 2025.

Despite this progress, regulators will expect to see that reforms are not just enacted on paper but embedded in day-to-day institutional practice. That distinction, between formal compliance and operational effectiveness, is precisely where the 2026 evaluation will probe hardest.

Institutions should use the months ahead to close gaps before assessors arrive. The following steps are non-negotiable:

• ● Conduct an internal gap analysis against FATF’s 40 Recommendations and the 11 IOs
  ● Update your Business Risk Assessment (BRA) to reflect the 2025 National Risk Assessment findings
  ● Review and stress-test your transaction monitoring rules for false negative rates and STR conversion quality
  ● Ensure beneficial ownership records are accurate, verified, and accessible in real time
  ● Document your risk-based approach to CDD with clear escalation procedures for high-risk customers
  ● Align policies with Federal Decree-Law No. 10/2025, particularly on proliferation financing and virtual assets
  ● Train staff across all levels, including front-line teams, on updated typologies and red flags
  ● Prepare an evidence pack for each IO your organisation is relevant to

Effective compliance monitoring software in Dubai is no longer a nice-to-have at this stage. It is the infrastructure that makes all of the above achievable, auditable, and demonstrable to assessors.