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The UAE’s removal from the FATF grey list in February 2024 marked a turning point, but it also came with an implicit expectation: that the country would continue strengthening its AML/CFT architecture rather than ease off once the immediate pressure had passed. Federal Decree-Law No. 10 of 2025 is the legislative centerpiece of that continued commitment.

The new law addresses gaps that the 2020 Mutual Evaluation identified, incorporates the findings of the UAE’s third National Risk Assessment published in April 2025, and aligns domestic legislation more closely with the FATF’s evolving global standards. It also reflects the realities of a financial landscape that looks very different from 2018, including the rapid growth of virtual assets, the increasing sophistication of financial crime, and the UAE’s expanded role as a global trading and investment hub.

The obligations introduced under Federal Decree-Law No. 10 are not achievable through manual processes alone. The volume, complexity, and speed of data required to meet the new law’s expectations demand a technology-led approach. This is where investing in robust AML compliance software becomes not just useful but essential. A capable platform enables regulated entities to:

• ● Screen customers and transactions against hundreds of global and local sanctions lists in real time
  ● Apply dynamic, risk-based scoring to customer profiles that updates automatically as new information emerges
  ● Monitor transactions continuously for patterns consistent with money laundering, proliferation financing, or tax evasion
  ● Generate and file Suspicious Transaction Reports within the required timeframes
  ● Maintain auditable records of every compliance decision for regulatory inspection
  ● Produce management information and board-level reporting on compliance performance
  ● Document the application of a risk-based approach in a format assessor can verify

Without the right technology embedded in your operations, the gap between what the law now requires and what your organization can demonstrate is likely to be significant.

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 Federal Decree-Law No. 10/2025, which came into effect on 14 October 2025, repealed and replaced the 2018 AML law, introducing standalone offences for proliferation financing, expanding predicate offences to include tax evasion, and explicitly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.

Organised by DNY Communications in collaboration with First Compliance by Adil Zone, this exclusive workshop addresses one of the most critical challenges facing compliance professionals today: “Mastering Advanced Due Diligence in the Age of AI.“

As artificial intelligence continues to transform the compliance landscape, organizations must adapt their Enhanced Due Diligence (EDD) frameworks to leverage these powerful technologies while maintaining robust governance and risk management practices.