208
Articles
3
Chapters
MOE
Issuing authority
2025
Effective since
AI
Cited answers from article text
Federal Decree-Law No. 10 of 2025 is one of the rulebooks issued by the Ministry of Economy — AML/CFT & Commercial Supervision. For compliance officers, legal teams, and advisors working under this regime, finding the right article quickly matters. Lexara indexes the full text of MoE AML/CFT and makes it searchable two ways: full-text and keyword search for rapid lookup, and AI Explorer for natural-language questions answered with citations to the exact article.
208 articles in 3 chapters, each with a plain-English summary by Arakan. The full text of every article is in the Laws Browser.
Article 2Article (2) Money Laundering Offence
Converting, transferring, concealing, disguising, acquiring, possessing, using, or assisting in the evasion of punishment in relation to Proceeds known (or reasonably suspected) to derive from a Predicate Offence constitutes Money Laundering; a Financial Institution/DNFBP and its staff must not engage in or facilitate any such act.
Article 3(1)-(2)Article (3) Financing of Terrorism Offence
Intentionally providing, collecting or making available Funds, by any means including digital systems, Virtual Assets or cryptographic technologies, with knowledge they will be used (in whole or in part) for a Terrorist Act, by a Terrorist or Terrorist Organization, or to finance travel/training for terrorism, constitutes Financing of Terrorism; a Financial Institution/DNFBP must not provide, collect, transmit or make available Funds or services for such purposes.
Article 3(3)-(4)Article (3) Proliferation Financing Offence
Intentionally providing, collecting or making available Funds, or performing other acts, with knowledge they will be used for the manufacture, acquisition, development, production, sale, supply, export, transport, storage or use of Weapons of Mass Destruction or related/dual-use materials, or pursuant to relevant UN Security Council resolutions, constitutes Proliferation Financing; a Financial Institution/DNFBP must not provide Funds or services for such purposes.
Article 4Article (4) Criminal Liability of Legal Persons
A Legal Person (which includes a Financial Institution or DNFBP constituted as a company or other legal entity) is criminally liable where a Money Laundering, Financing of Terrorism or Proliferation Financing crime is intentionally committed in its name or for its account, without prejudice to the personal criminal liability of the individual perpetrator and to any administrative penalties.
Article 5(1)Article (5) Provisional Measures - Cessation/Suspension of Transactions
Where the Chief of the Unit orders, without prior notice, the cessation or temporary suspension of a Transaction suspected of being related to the Crime (for up to ten (10) working days), the Financial Institution/DNFBP/VASP handling that Transaction must give effect to the order without notifying the Customer.
Article 5(2)Article (5) Provisional Measures - Freezing of Funds
Where the Chief of the Unit orders, without prior notice, the Freezing of Funds suspected of being related to the Crime and held with a Financial Institution, DNFBP or VASP (for up to thirty (30) days, extendable by the Attorney General or delegate), the institution holding the Funds must give effect to the freezing order without notifying the Customer.
Article 5(4)Article (5) Provisional Measures - Lifting of Freezing Order
A Financial Institution, DNFBP or VASP must lift a Freezing order upon its cancellation by the Chief of the Unit, or upon expiry of the thirty (30) day period referred to in Clause (2), unless that period has been extended.
Article 9(1)Article (9) Investigation Procedures - Access to Accounts and Records
Where the Public Prosecution (on its own initiative or on request of Law Enforcement Authorities) orders direct access to accounts, registers, documents and records held by a Financial Institution/DNFBP as a third party, the institution must provide that access as ordered.
Article 10Article (10) Disclosure - Cross-Border Movement of Currency and Valuables
Any person entering or departing the State carrying currencies, bearer negotiable instruments, precious metals or valuable stones must make a disclosure in accordance with the disclosure system issued by the Federal Authority for Identity, Citizenship, Customs and Port Security, in coordination with the Central Bank; this is directly relevant to Financial Institutions/DNFBPs (e.g. dealers in precious metals and stones, or entities physically transporting cash) engaged in cross-border movement of
Article 11Article (11) The Financial Intelligence Unit - Submission of Suspicious Transaction Reports
All Suspicious Transaction Reports and related information must be submitted exclusively to the Financial Intelligence Unit by all Financial Institutions, Designated Non-Financial Businesses and Professions, and Virtual Asset Service Providers.
Article 11(1)Article (11) The Financial Intelligence Unit - Provision of Additional Information on Request
The Financial Intelligence Unit may request from Financial Institutions, DNFBPs and VASPs the provision of any additional information or documents related to reports and information already received, or any other information the Unit deems necessary, within the timeframe and in the form prescribed by the Unit; the institution must comply with such requests.
Article 17(1)Article (17) Administrative Penalties
Financial Institutions, DNFBPs, VASPs, and NPOs are subject to a range of administrative penalties (warning; fine of AED 10,000 to AED 5,000,000 per violation; prohibition from engaging in the sector; restriction of powers of board/executive/managerial personnel or owners including appointment of a temporary supervisor; suspension of directors/board members/executive or supervisory personnel or requesting their replacement; suspension or restriction of activity/profession; revocation of license)
Article 17(2)Article (17) Administrative Penalties
Where the Supervisory Authority imposes an administrative penalty, it may order the entity to submit periodic reports on the measures undertaken to remedy the violation; the entity must comply with such order.
Article 17(3)Article (17) Administrative Penalties
The Supervisory Authority may impose an incremental (higher) administrative fine where the same violation recurs within one year of the prior fine, creating heightened exposure for repeat violations.
Article 18(1)(a)Article (18) Reporting of Suspicious Transactions
Where a Financial Institution, DNFBP, or VASP suspects or has reasonable grounds to suspect that a transaction or funds, in whole or in part, represent proceeds of or are related to or intended for use in Money Laundering, Terrorism Financing, or Proliferation Financing (regardless of value), it must notify the Financial Intelligence Unit without delay and directly, via a detailed report through the Unit's designated electronic system or other approved means.
Article 18(1)(b)Article (18) Reporting of Suspicious Transactions
The reporting entity must furnish any additional information requested by the Financial Intelligence Unit in connection with a Suspicious Transaction Report, without invoking confidentiality provisions as grounds for refusal.
Article 19(1)(a)Article (19) Preventive Measures and Customer Due Diligence Obligations
Financial Institutions, DNFBPs, and VASPs must identify, understand, manage, assess, document, and continuously update the ML/TF/PF risks within their business scope using a risk-based approach, retain the risk assessment study and related information, and provide it to the Supervisory Authority upon request.
Article 19(1)(b)Article (19) Preventive Measures and Customer Due Diligence Obligations
Financial Institutions, DNFBPs, and VASPs must implement Customer Due Diligence measures and continuous monitoring procedures, scaled to risk dimensions and national risk assessment outcomes, and retain the information obtained from such measures (including determining when identification of Customer/Beneficial Owner may be deferred, per Executive Regulations).
Article 19(1)(c)Article (19) Preventive Measures and Customer Due Diligence Obligations
Financial Institutions, DNFBPs, and VASPs must refrain from opening or maintaining accounts, or conducting financial or commercial transactions, under anonymous, fictitious, alias, or numbered names, or providing any services to such accounts.
Article 19(1)(d)Article (19) Preventive Measures and Customer Due Diligence Obligations
Financial Institutions, DNFBPs, and VASPs must establish internal AML/CFT policies, controls, and procedures, approved by senior management, to manage and mitigate identified risks, and must review and update them continuously, ensuring application across all branches and majority-owned subsidiaries.
Article 19(1)(e)Article (19) Preventive Measures and Customer Due Diligence Obligations
Financial Institutions, DNFBPs, and VASPs must implement forthwith the instructions issued by the Executive Office or any other Competent Authority concerning Targeted Financial Sanctions.
Article 19(1)(f)Article (19) Preventive Measures and Customer Due Diligence Obligations
Financial Institutions, DNFBPs, and VASPs must retain all records, documents, and data relating to domestic and international transactions, ensuring immediate availability to Competent Authorities upon request, as further specified in the Executive Regulations.
Article 20Article (20) Licensing Requirement
No natural or legal person may engage in Financial Activities, Designated Non-Financial Businesses and Professions, or Virtual Asset Service Provider activities without first obtaining a license, registration, or enrolment from the Competent Authority or relevant Supervisory Authority.
Article 21(4)(a)Article (21) International Cooperation
Upon an order made pursuant to a mutual legal assistance request from a foreign judicial authority, Financial Institutions, DNFBPs, and VASPs must provide records they hold to support identification, tracing, evaluation, seizure, freezing, or confiscation of funds/criminal property.
Article 24Article (24) Confidentiality of Information
Information obtained in relation to Suspicious Transactions or Crimes under the Decree by Law is deemed confidential and may only be disclosed to the extent necessary for use in investigations or proceedings under the Decree by Law, or as otherwise permitted by law; this underpins the prohibition on tipping-off.
Article 26(1)Article (26) Penalties for Money Laundering, Financing of Terrorism and Proliferation Financing
Prohibited conduct: committing the Crime of Money Laundering. Penalty: imprisonment of not less than 1 year and not exceeding 10 years, together with a fine of not less than AED 100,000 and not exceeding AED 5,000,000, or an amount equivalent to the value of the relevant Criminal Property, whichever is greater.
Article 26(2)Article (26) Penalties for Money Laundering, Financing of Terrorism and Proliferation Financing
Prohibited conduct: committing Money Laundering in aggravating circumstances (exploiting position/professional authority; through a Non-Profit Organization; through an organized criminal group; where the predicate offence is among specified serious crimes; or recidivism). Penalty: temporary imprisonment and a fine of not less than AED 1,000,000 and not exceeding AED 10,000,000, or an amount equivalent to twice the value of the relevant Criminal Property, whichever is greater.
Article 26(3)Article (26) Penalties for Money Laundering, Financing of Terrorism and Proliferation Financing
Prohibited conduct: committing the Crime of Financing of Terrorism. Penalty: life imprisonment or temporary imprisonment of not less than 10 years, and a fine of not less than AED 1,000,000 and not exceeding AED 10,000,000, or an amount equivalent to twice the value of the relevant Criminal Property, whichever is greater.
Article 26(4)Article (26) Penalties for Money Laundering, Financing of Terrorism and Proliferation Financing
Prohibited conduct: committing the Crime of Proliferation Financing. Penalty: temporary imprisonment and a fine of not less than AED 1,000,000 and not exceeding AED 10,000,000, or an amount equivalent to twice the value of the relevant Criminal Property, whichever is greater.
Article 26(5)Article (26) Penalties for Money Laundering, Financing of Terrorism and Proliferation Financing
Prohibited conduct: attempting to commit Money Laundering, Financing of Terrorism, or Proliferation Financing. Penalty: same penalty as prescribed for the consummated crime.
Article 27(1)Article (27) Liability of Legal Persons
Prohibited conduct: a legal person's representatives, directors, or agents committing Money Laundering, Financing of Terrorism, or Proliferation Financing on its behalf or in its name. Penalty: a fine of not less than AED 5,000,000 and not exceeding AED 100,000,000, or an amount equivalent to the value of the Criminal Property involved, whichever is greater, imposed on the legal person itself.
Article 27(2)Article (27) Liability of Legal Persons
Prohibited conduct: a legal person's representatives, directors, or agents committing, on its behalf or in its name, any of the offences under Articles 28, 29, 30, 32, 33, 34, or 35. Penalty: a fine of not less than AED 200,000 and not exceeding AED 10,000,000, imposed on the legal person.
Article 27(3)Article (27) Liability of Legal Persons
Consequence: upon conviction of a legal person for Financing of Terrorism or Proliferation Financing, the Court shall order its dissolution and the closure of the premises where its activity is conducted.
Article 27(4)Article (27) Liability of Legal Persons
Consequence: upon conviction of a legal person for Money Laundering, or in the event of a violation of Article 10 of the Decree by Law, the Court may (at its discretion) order its dissolution and the closure of its premises.
Article 27(5)Article (27) Liability of Legal Persons
Prohibited conduct: where a legal person is liable under Clauses (1) or (2) of Article 27, the person responsible for actual management of the legal person shall be personally punished by imprisonment and a fine (or either) if proven aware of the crime and that its commission was due to their breach of the duties of their position.
Article 27(6)Article (27) Liability of Legal Persons
Consequence: upon pronouncing a conviction, the Court may order publication of a summary of the judgment by appropriate means, at the expense of the convicted person.
Article 28Article (28) Penalty for Violation of Suspicious Transaction Reporting Obligations
Prohibited conduct: deliberately or through gross negligence violating the Article 18 obligation to report Suspicious Transactions to the Unit. Penalty: imprisonment and a fine of not less than AED 100,000 and not exceeding AED 1,000,000, or either of these two penalties.
Article 29(1)Article (29) Penalties for Tipping-Off and Breach of Fund Management Duties
Prohibited conduct: notifying or warning another person, disclosing information related to Transactions under review concerning Suspicious Transactions, or revealing that Competent Authorities are conducting inquiries/investigations, in contravention of Article 24's confidentiality requirement (tipping-off). Penalty: imprisonment and a fine of not less than AED 50,000, or either of these two penalties.
Article 29(2)Article (29) Penalties for Tipping-Off and Breach of Fund Management Duties
Prohibited conduct: deliberately or through gross negligence breaching duties in managing funds entrusted to the person, or violating any order issued by a competent authority regarding Seizure, Freezing, or other precautionary measures. Penalty: imprisonment and a fine of not less than AED 50,000, or either of these two penalties.
Article 29(3)Article (29) Penalties for Tipping-Off and Breach of Fund Management Duties
Aggravated penalty: where the acts under Clauses (1) or (2) of Article 29 result in the inability to seize the Proceeds, or in their destruction or loss of value, the penalty is imprisonment of not less than one year and a fine equal to the value of the Proceeds (not less than AED 100,000).
Article 30(1)Article (30) Penalties for Possession/Concealment of Illicit Funds and Virtual Asset Anonymity Offences
Prohibited conduct: possessing, concealing, or conducting any transaction in funds where there are sufficient indications or evidence suggesting the illegitimacy of their source, or concealment of the Beneficial Owner thereof. Penalty: imprisonment of not less than three (3) months and a fine of not less than AED 50,000, or either of these two penalties.
Article 30(2)Article (30) Penalties for Possession/Concealment of Illicit Funds and Virtual Asset Anonymity Offences
Prohibited conduct: promoting, offering for sale, providing services relating to, or dealing in Virtual Assets characterized by total anonymity, or that prevent/obstruct Competent Authorities from tracing the transaction or its parties, or unlicensed accounts/technologies enabling such concealment. Penalty: imprisonment of not less than three (3) months and a fine of not less than AED 50,000, or either of these two penalties.
Article 32Article (32) Penalty for Unlicensed Activity
Prohibited conduct: violating Article 20 by engaging in Financial Activities, DNFBP, or Virtual Asset Service Provider activities without the required license, registration, or enrolment. Penalty: imprisonment and a fine of not less than AED 200,000 and not exceeding AED 10,000,000, or either of these two penalties.
Article 33Article (33) Penalty for Violation of Targeted Financial Sanctions
Prohibited conduct: violating instructions issued by the Executive Office or any other Competent Authority relating to Targeted Financial Sanctions. Penalty: imprisonment and a fine of not less than AED 20,000, or either of these two penalties.
Article 34Article (34) Penalty for Violation of Article (10) and Related Information Obligations
Prohibited conduct: violating Article 10 of the Decree by Law, refraining from providing additional information where requested, deliberately concealing information required to be disclosed, or knowingly providing false information. Penalty: imprisonment and a fine, or either of these two penalties (amount not specified in this Article).
Article 35(1)Article (35) Penalties Relating to Beneficial Ownership Information and Account Misuse
Prohibited conduct: intentionally providing false or misleading information concerning the Beneficial Owner to any Competent Authority, or to a Financial Institution, DNFBP, or VASP requesting such information. Penalty: imprisonment and a fine of not less than AED 20,000, or either of these two penalties.
Article 35(2)Article (35) Penalties Relating to Beneficial Ownership Information and Account Misuse
Prohibited conduct: unlawfully enabling another person to benefit from one's account with a Financial Institution or Virtual Asset Service Provider, while knowing or having sufficient grounds to believe such use is intended for misuse of the account. Penalty: imprisonment and a fine, or either of these two penalties (amount not specified in this Article).
Article 35(3)Article (35) Penalties Relating to Beneficial Ownership Information and Account Misuse
Prohibited conduct: violating Clause (1) of Article 19 (the core preventive measures: risk assessment, CDD, anonymous-account prohibition, internal policies, TFS implementation, record-keeping) or paragraphs (a), (c), and (d) of Clause (2) of Article 19 (obligations of the Registrar/Competent Authorities regulating Legal Arrangements, and of companies/nominee directors/nominee shareholders, and of Legal Arrangements/Trustees, as regulated by the Executive Regulations). Penalty: imprisonment and
Article 3(1)Article (3) Nature of Financial Institutions and Designated Non-Financial Businesses and Professions
Commercial Gaming Operators (including on vessels/marine craft) are captured as DNFBPs subject to AML/CFT obligations when a single financial transaction, or several transactions that appear linked, equal or exceed AED 11,000 (gaming-chip-only transactions excluded).
Article 3(3)Article (3) Nature of Financial Institutions and Designated Non-Financial Businesses and Professions
Dealers in valuable metals and precious stones are captured as DNFBPs subject to AML/CFT obligations when carrying out a single cash transaction, or several transactions that appear linked, whose value equals or exceeds AED 55,000.
Article 5(1)-2Article (5) Risk Identification and Risk Mitigation
Financial Institutions and DNFBPs must identify, understand, manage and assess their money laundering/terrorism financing/proliferation financing (crime) risks in a manner proportionate to the nature and size of their business, having regard to the risk-based approach and the results of the National Risk Assessment.
Article 5(1)(a)Article (5) Risk Identification and Risk Mitigation
Before determining the overall risk level and the appropriate risk mitigation measures, firms must consider all relevant risk factors, including customer risk, country/geographic risk, and product, service, transaction and delivery-channel risk.
Article 5(1)(b)Article (5) Risk Identification and Risk Mitigation
Firms must document the processes used to identify and assess risks and related information, retain the relevant risk assessment study, update it on an ongoing basis, and provide it to the concerned authorities upon request.
Article 5(2)-2Article (5) Risk Identification and Risk Mitigation
Firms must mitigate the crime risks identified under Clause (1), taking into account the risk-based approach, National Risk Assessment results and sectoral assessments.
Article 5(2)(a)Article (5) Risk Identification and Risk Mitigation
Firms must establish internal policies, controls and procedures approved by Senior Management enabling them to manage and mitigate identified risks, and must review and update these on an ongoing basis.
Article 5(2)(b)Article (5) Risk Identification and Risk Mitigation
Firms must ensure internal policies, controls and procedures are proportionate to the nature and size of their business, monitor their implementation, assess their effectiveness, and enhance them where necessary in accordance with Article (21).
Article 5(2)(c)Article (5) Risk Identification and Risk Mitigation
For identified risks, firms must apply Enhanced Due Diligence (EDD) measures, including: obtaining/verifying additional customer/occupation/Beneficial Owner/funds information from public/open sources; obtaining information on the purpose of the relationship or expected/actual transactions; updating CDD information more regularly; taking reasonable measures to identify source of funds and wealth; increasing the degree/level of ongoing monitoring and scrutinizing transaction patterns; and, where r
Article 5(2)(c)(7)Article (5) Risk Identification and Risk Mitigation
As part of EDD for identified risks, firms must obtain Senior Management approval before commencing or continuing a Business Relationship with the customer.
Article 5(3)Article (5) Risk Identification and Risk Mitigation
Where low risk is identified and after fulfilling the risk identification/mitigation requirements, firms may (in coordination with the Supervisory Authority) apply Simplified Due Diligence (SDD), but must in all cases ensure full implementation of Targeted Financial Sanctions instructions issued by the Executive Office or other Competent Authorities, and SDD may not be applied where there is suspicion that a crime has been committed.
Article 5(4)(a)Article (5) Risk Identification and Risk Mitigation
Where high risks related to Proliferation Financing are identified, firms must adopt enhanced internal controls to detect and prevent violations, non-implementation, or circumvention of Targeted Financial Sanctions instructions, and conduct ongoing enhanced scrutiny of the Business Relationship to ensure full compliance.
Article 5(4)(b)Article (5) Risk Identification and Risk Mitigation
Firms must maintain documented records of the Proliferation Financing risk-mitigation measures taken and make them available to the competent authorities upon request.
Article 5(4)(c)Article (5) Risk Identification and Risk Mitigation
Firms must conduct periodic reviews of internal controls in line with changes in the level of Proliferation Financing risk.
Article 6(1)Article (6) Customer Due Diligence and Beneficial Owner Identification Procedures
Firms must verify the identity of the Customer and the Beneficial Owner before or during the establishment of a Business Relationship or the opening of an account, or prior to carrying out a Transaction for a Customer with whom no relationship exists.
Article 6(2)Article (6) Customer Due Diligence and Beneficial Owner Identification Procedures
In cases of low crime risk, firms may defer completion of customer identity verification until after the Business Relationship is established, provided verification is completed as soon as possible, the deferral is necessary to avoid disrupting normal business, and appropriate and effective measures are applied to control the risks in the interim.
Article 6(3)Article (6) Customer Due Diligence and Beneficial Owner Identification Procedures
Firms must take measures to manage risks in circumstances where the Customer is able to benefit from the Business Relationship prior to completion of the verification process.
Article 7(1)Article (7) Customer Due Diligence and Beneficial Owner Identification Procedures
Firms must apply Customer Due Diligence measures upon commencement of a Business Relationship, where there is suspicion of a Crime, or where there are doubts as to the accuracy or adequacy of previously obtained Customer identification data.
Article 7(2)(a)Article (7) Customer Due Diligence and Beneficial Owner Identification Procedures
Financial Institutions must apply Customer Due Diligence measures when conducting occasional Transactions for a Customer amounting to or exceeding AED 55,000, whether as a single Transaction or several Transactions that appear to be linked.
Article 7(2)(b)Article (7) Customer Due Diligence and Beneficial Owner Identification Procedures
Financial Institutions must apply Customer Due Diligence measures when conducting occasional Transactions in the form of Wire Transfers amounting to or exceeding AED 3,500.
Article 8(1)Article (8) Customer Due Diligence and Beneficial Owner Identification Procedures
Firms must scrutinize transactions carried out throughout the Business Relationship to ensure they are consistent with information held on the Customer, the nature of their activities and the risks they represent, including, where necessary, the source of funds.
Article 8(2)Article (8) Customer Due Diligence and Beneficial Owner Identification Procedures
Firms must ensure documents, data or information obtained through CDD are up to date and relevant by reviewing records, with particular emphasis on records relating to categories of High-Risk Customers.
Article 9(1)(a)Article (9) Customer Due Diligence and Beneficial Owner Identification Procedures
For natural person Customers, firms must obtain the name as stated in the identity card or travel document, nationality, address, date and place of birth and, where applicable, the employer's name and address, together with a true copy of a valid identity card or travel document, verified from a reliable and independent source.
Article 9(1)(b)Article (9) Customer Due Diligence and Beneficial Owner Identification Procedures
For Legal Person/Legal Arrangement Customers, firms must obtain: name, legal form, memorandum of association, tax registration number (if subject to corporate tax) and unique reference number if any; address of registered office/principal place of business (plus legal representative details and supporting evidence if foreign); articles of association or equivalent approved documents; and names of persons holding Senior Management positions.
Article 9(2)Article (9) Customer Due Diligence and Beneficial Owner Identification Procedures
Firms must verify that any person acting on behalf of the Customer is duly authorized to do so, and must identify that person in accordance with Clause (1).
Article 9(3)Article (9) Customer Due Diligence and Beneficial Owner Identification Procedures
Firms must understand the purpose and intended nature of the Business Relationship and obtain information relating thereto where necessary.
Article 9(4)Article (9) Customer Due Diligence and Beneficial Owner Identification Procedures
Firms must understand the nature of the Customer's business and its ownership and control structure.
Article 10(1)(a)Article (10) Customer Due Diligence and Beneficial Owner Identification Procedures
For Legal Person Customers, firms must identify the natural person who ultimately owns, individually or jointly, a controlling ownership interest or shares of 25% or more.
Article 10(1)(b)Article (10) Customer Due Diligence and Beneficial Owner Identification Procedures
Where there is doubt as to the person identified under (a), or that such person is the Beneficial Owner, or where no natural person exercises control through ownership, firms must identify the natural person who exercises legal or actual control over the Legal Person by any other means, directly or indirectly.
Article 10(1)(c)Article (10) Customer Due Diligence and Beneficial Owner Identification Procedures
Where no natural person is identified under (a) or (b), firms must identify the relevant natural person(s) holding a Senior Management position as the Beneficial Owner of last resort.
Article 10(2)(a)Article (10) Customer Due Diligence and Beneficial Owner Identification Procedures
For Legal Arrangement Customers, firms must identify the Trustee, Settlor, Trust Protector, Beneficiaries or classes of Beneficiaries, and the powers/authorities granted to them, where no Beneficiaries are identifiable at the time the Trust is established.
Article 10(2)(b)Article (10) Customer Due Diligence and Beneficial Owner Identification Procedures
Firms must identify any other natural person exercising ultimate effective control over the Trust, whether directly or indirectly, including through a chain of ownership or control.
Article 10(2)(c)Article (10) Customer Due Diligence and Beneficial Owner Identification Procedures
Firms must obtain adequate information regarding the Beneficial Owner to enable identification at the time of payment or when the Beneficial Owner intends to exercise legally acquired rights.
Article 10(2)(d)Article (10) Customer Due Diligence and Beneficial Owner Identification Procedures
Firms must identify natural persons holding equivalent or similar positions in other types of Legal Arrangements.
Article 10(2)(e)Article (10) Customer Due Diligence and Beneficial Owner Identification Procedures
Where a Legal Person is a party to the Legal Arrangement, firms must identify the Beneficial Owner of that Legal Person in accordance with Article (10).
Article 11-2Article (11) Customer Due Diligence and Beneficial Owner Identification Procedures
Where the Customer, or the controlling owner, is a company listed on a securities market subject to disclosure requirements ensuring sufficient transparency of Beneficial Owner identification (or its majority-owned subsidiary), firms are permitted not to identify or verify the identity of any shareholder or Beneficial Owner, and may instead source identity information from publicly available registers, the Customer, or other reliable sources.
Article 12(1)(a)Article (12) Customer Due Diligence and Beneficial Owner Identification Procedures
Financial Institutions must apply Due Diligence and ongoing monitoring to the beneficiary of life insurance and other investment-related insurance policies as soon as the beneficiary is identified or designated; where the beneficiary is designated by name, that person's name must be obtained (natural person, Legal Person or Legal Arrangement).
Article 12(1)(b)Article (12) Customer Due Diligence and Beneficial Owner Identification Procedures
Where the beneficiary is designated by category or description (e.g. family relationship or by will/estate), firms must obtain sufficient information about the beneficiary to be able to identify them at the time of payment of compensation or entitlements.
Article 12(1)(c)Article (12) Customer Due Diligence and Beneficial Owner Identification Procedures
In all cases, firms must verify the beneficiary's identity at the time of payment of compensation/entitlements or upon exercise of any rights related to the policy.
Article 12(2)Article (12) Customer Due Diligence and Beneficial Owner Identification Procedures
Financial Institutions must treat the beneficiary of life insurance policies as a risk factor when determining whether Enhanced Customer Due Diligence applies; where the beneficiary is a Legal Person or Legal Arrangement presenting high risk, Enhanced Due Diligence must be applied, including reasonable procedures to identify and verify the Beneficial Owner of that beneficiary at the time of payment of compensation/entitlements or exercise of rights.
Article 13Article (13) Customer Due Diligence and Beneficial Owner Identification Procedures
Firms must apply Customer Due Diligence measures to existing Customers and Business Relationships as at the entry into force of this Resolution, at such times as they deem appropriate based on materiality and risk, and must ensure the adequacy of previously obtained data where Due Diligence was applied before the Resolution's entry into force.
Article 14(1)Article (14) Customer Due Diligence and Beneficial Owner Identification Procedures
Firms are prohibited from establishing or continuing a Business Relationship, or executing a Transaction, where they are unable to apply Customer Due Diligence measures, and must consider submitting a Suspicious Transaction Report to the Unit whenever necessary.
Article 14(2)Article (14) Customer Due Diligence and Beneficial Owner Identification Procedures
Where firms suspect the commission of a Crime, they may refrain from applying Customer Due Diligence measures if they have reasonable grounds to believe doing so would alert the Customer, but must submit a Suspicious Transaction Report to the Unit stating the reasons for not applying such measures.
Article 15(1)Article (15) Customer Due Diligence and Beneficial Owner Identification Procedures
Firms must refrain from dealing with Shell Banks in any manner whatsoever, including opening bank accounts for them or accepting funds or deposits from them.
Article 15(2)Article (15) Customer Due Diligence and Beneficial Owner Identification Procedures
Firms must refrain from opening or maintaining anonymous accounts or accounts held under obviously fictitious names.
Article 16(1)(a)(1)Article (16) Politically Exposed Persons
In respect of foreign Politically Exposed Persons, firms must establish appropriate risk management systems to determine whether the Customer or the Beneficial Owner is a Politically Exposed Person.
Article 16(1)(a)(2)Article (16) Politically Exposed Persons
Firms must obtain approval from Senior Management prior to establishing or continuing a Business Relationship with existing Customers identified as foreign Politically Exposed Persons.
Article 16(1)(a)(3)Article (16) Politically Exposed Persons
Firms must take Reasonable Measures to identify the source of funds and wealth of Customers and Beneficial Owners identified as foreign Politically Exposed Persons.
Article 16(1)(a)(4)Article (16) Politically Exposed Persons
Firms must conduct enhanced ongoing monitoring of the Business Relationship with foreign Politically Exposed Persons.
Article 16(1)(b)(1)Article (16) Politically Exposed Persons
In respect of domestic Politically Exposed Persons and persons entrusted with a prominent function in an international organization, firms must take adequate measures to determine whether the Customer or Beneficial Owner falls within these categories.
Article 16(1)(b)(2)Article (16) Politically Exposed Persons
Where a high-risk Business Relationship exists with a domestic Politically Exposed Person or international organization official, firms must apply the same measures as for foreign PEPs: Senior Management approval, source of funds/wealth measures, and enhanced ongoing monitoring.
Article 16(2)Article (16) Politically Exposed Persons
Financial Institutions concerned with life insurance policies must take Reasonable Measures to determine whether the beneficiary or Beneficial Owner is a Politically Exposed Person prior to payment of compensation/entitlements or exercise of related rights; where higher risk is identified, they must inform Senior Management prior to payment, conduct enhanced scrutiny of the entire Business Relationship, and consider submitting a Suspicious Transaction Report.
Article 17Article (17) Suspicious Transaction Reports
Firms must establish indicators through which they can identify suspicion of a Crime for the purpose of submitting Suspicious Transaction Reports, and must update these indicators on an ongoing basis in line with the development and diversification of crime methods, in compliance with Supervisory Authority instructions.
Article 18(1)(a)-2Article (18) Suspicious Transaction Reports
Where firms suspect, or have reasonable grounds to suspect, that a Transaction or attempted Transaction, or funds, in whole or in part, constitute proceeds of, are related to, or are intended for use in a Crime, regardless of value, they must, without invoking banking or professional secrecy or contractual liability, immediately and without delay notify the Unit by submitting a Suspicious Transaction Report containing all available data, through the Unit's electronic system or other approved mea
Article 18(1)(b)-2Article (18) Suspicious Transaction Reports
Firms must promptly respond to any request from the Unit for additional information.
Article 19(1)Article (19) Suspicious Transaction Reports
Firms, together with their directors, officers and employees, are prohibited from disclosing, directly or indirectly, to the Customer or any other person that a Suspicious Transaction Report has been or is about to be submitted, or any related information, or that an investigation is being conducted, without prejudice to permitted information sharing with branches and subsidiaries at Financial Group level under Article (32).
Article 20(1)Reliance on Third Parties
When relying on a third party to perform Customer Due Diligence, the Financial Institution/DNFBP/VASP remains fully responsible for the accuracy of the CDD measures performed by that third party.
Article 20(1)(a)Reliance on Third Parties
Firms relying on a third party for CDD must ensure the third party is regulated and supervised and complies with CDD and record-keeping requirements under this Resolution.
Article 20(1)(b)Reliance on Third Parties
Firms relying on a third party must immediately obtain the identification data/CDD information collected by that third party, and ensure they can obtain copies of underlying documents without delay upon request.
Article 20(2)Reliance on Third Parties
Where relying on a third party that is part of the same Financial Group, the firm must ensure the Group applies CDD/PEP/record-keeping/anti-crime programs consistent with Divisions Three, Four and Eleven and Article 32, and that the group is supervised by a competent authority.
Article 20(2)(b)Reliance on Third Parties
Firms relying on a group entity must ensure that any high country risks connected with the reliance are adequately mitigated through the Group's anti-crime policies and controls.
Article 20(3)Reliance on Third Parties
Reliance on a third party excludes outsourcing or agency arrangements; where such arrangements are used, the firm must ensure they are carried out under its own internal policies, subject to its own supervision and control, with fitness/propriety standards and effective audit applied to staff.
Article 21Internal Supervision and Foreign Branches and Subsidiaries
Firms must maintain internal anti-crime policies, controls and procedures approved by Senior Management, proportionate to identified Crime risk and to the nature/size of their activities, and review/update them on an ongoing basis.
Article 21(1)Internal Supervision and Foreign Branches and Subsidiaries
Internal policies must include CDD measures, including risk management procedures for Business Relationships prior to completion of the verification process.
Article 21(2)Internal Supervision and Foreign Branches and Subsidiaries
Internal policies must include procedures for reporting Suspicious Transactions.
Article 21(3)Internal Supervision and Foreign Branches and Subsidiaries
Firms must have appropriate anti-crime compliance management arrangements, including appointment of a Compliance Officer at management level.
Article 21(4)Internal Supervision and Foreign Branches and Subsidiaries
Firms must apply screening procedures to ensure high standards of fitness and propriety in the appointment of employees.
Article 21(5)Internal Supervision and Foreign Branches and Subsidiaries
Firms must prepare periodic anti-crime programs and workshops to build the capacities of compliance staff and other relevant employees.
Article 21(6)Internal Supervision and Foreign Branches and Subsidiaries
Firms must maintain an independent audit function to test the effectiveness and adequacy of internal anti-crime policies, controls and procedures.
Article 22Duties of the Compliance Officer
Firms must appoint a Compliance Officer at management level, independent in decision-making, and possessing appropriate competence and experience.
Article 22(1)Duties of the Compliance Officer
The Compliance Officer must monitor Transactions related to the Crime.
Article 22(2)Duties of the Compliance Officer
The Compliance Officer must review records and receive, examine and assess Suspicious Transaction data, deciding whether to notify the Unit or retain the matter (stating reasons), in full confidentiality.
Article 22(3)Duties of the Compliance Officer
The Compliance Officer must review AML/CFT/PF internal systems and procedures, assess consistency with the Decree-Law/Resolution, evaluate compliance levels, propose updates, and prepare periodic reports to Senior Management (copied to the Supervisory Authority on request), including Senior Management observations/decisions.
Article 22(4)Duties of the Compliance Officer
The Compliance Officer must develop, implement and document ongoing training programs for employees regarding the Crime and methods of combating it.
Article 22(5)Duties of the Compliance Officer
The Compliance Officer must cooperate with the Supervisory Authority and the Unit, providing requested data and enabling access to records/documents necessary for their competencies.
Article 23(1)High-Risk Countries
Firms must apply Enhanced Customer Due Diligence measures proportionate to risk for Business Relationships or Transactions involving persons from countries identified by the National Committee as high-risk, or with AML/CFT/PF deficiencies.
Article 23(2)High-Risk Countries
Firms must apply countermeasures and any other measures required by the Supervisory Authority (on its own initiative or per the National Committee) in relation to high-risk/deficient countries.
Article 24(1)Requirements Relating to New Technologies
Firms must identify and assess ML/TF/PF risks arising from new products, new business practices (including new delivery mechanisms), and new or developing technologies, for both new and pre-existing products.
Article 24(2)Requirements Relating to New Technologies
Firms must assess such risks prior to the launch or use of products, practices or technologies, and take appropriate measures to manage and mitigate those risks.
Article 25(1)Record-Keeping
Firms must retain all records, documents, instruments and data relating to domestic and international financial/cash Transactions and commercial dealings for not less than five (5) years from completion of the Transaction or termination of the Business Relationship, and make them available to concerned authorities promptly upon request.
Article 25(2)Record-Keeping
Firms must retain all CDD, ongoing monitoring, account file, correspondence, ID document, STR, analysis, CCTV and ATM recording records for not less than five (5) years from the latest of: termination of the Business Relationship, account closure, completion of an occasional Transaction, completion of a Supervisory Authority inspection, completion of an investigation, or issuance of a final court judgment.
Article 25(3)Record-Keeping
Firms must organize retained records, documents and instruments to permit reconstruction of individual Transactions, data analysis, and tracing of financial transactions, so as to provide evidence for prosecution where necessary.
Article 25(4)Record-Keeping
Firms must make all customer information -- including CDD, ongoing monitoring and results, records, files, documents, correspondence and related forms -- available to concerned authorities promptly upon request.
Article 26(1)(a)Correspondent Banking Relationship
Prior to entering a Correspondent Banking Relationship, Financial Institutions must refrain from entering into or continuing a relationship with Shell Banks or with institutions that permit their accounts to be used by Shell Banks.
Article 26(1)(b)Correspondent Banking Relationship
Financial Institutions must collect sufficient information on any respondent Correspondent Institution to identify it, understand the nature of its business, and determine its reputation and supervision level (including any Crime-related investigation or supervisory action) through publicly available information.
Article 26(1)(c)Correspondent Banking Relationship
Financial Institutions must assess the anti-crime controls applied by the respondent institution.
Article 26(1)(d)Correspondent Banking Relationship
Financial Institutions must obtain Senior Management approval prior to establishing a new Correspondent Banking Relationship.
Article 26(1)(e)Correspondent Banking Relationship
Financial Institutions must understand the anti-crime responsibilities of each institution in a Correspondent Banking Relationship.
Article 26(2)-2Correspondent Banking Relationship
For Payable-Through Accounts, Financial Institutions must ensure the respondent institution has applied Due Diligence on customers with direct access to such accounts and can provide relevant CDD information upon request.
Article 27(1)-2Money or Value Transfer Services (MVTS)
Money or Value Transfer Service Providers must be licensed by or registered with the concerned Supervisory Authority and comply with anti-crime controls.
Article 27(2)-2Money or Value Transfer Services (MVTS)
MVTS providers must maintain an updated list of their agents, make it available to concerned authorities, include agents in anti-crime programs, and monitor agents' compliance with those programs.
Article 28(1)Wire Transfers
Financial Institutions must verify the accuracy of originator information for international Wire Transfers equal to or exceeding AED 3,500, and ensure such transfers are accompanied by full originator/beneficiary name, account number (or unique transaction reference), and originator address/ID number/DOB/customer identification number.
Article 28(2)Wire Transfers
Where multiple international Wire Transfers from a single originator are bundled in a batch file, the file must include accurate originator data and complete, traceable beneficiary information, plus the originator's account number or a unique transaction reference number.
Article 28(3)Wire Transfers
International Wire Transfers below AED 3,500 must still be accompanied by the data required under Clause (1), without needing accuracy verification, unless there is suspicion of the Crime.
Article 28(4)Wire Transfers
Financial Institutions originating domestic Wire Transfers must ensure the same originator data as Clause (1) accompanies the transfer, unless such data is otherwise available to the Beneficiary Financial Institution/authorities through other means.
Article 28(5)Wire Transfers
Where domestic transfer information is available to the Beneficiary Financial Institution/authorities via other means, the originating Financial Institution need only include the account number or a traceable unique transaction reference, but must provide the full data within three (3) Working Days of a request from the Beneficiary Financial Institution or concerned authorities.
Article 28(6)Wire Transfers
Financial Institutions are prohibited from executing Wire Transfers that fail to comply with the conditions set out in Article 28.
Article 28(7)Wire Transfers
Originating Financial Institutions must retain all information collected regarding the originator and beneficiary in accordance with Article 25.
Article 28(8)Wire Transfers
Financial Institutions must, when processing Wire Transfers, apply freezing and transaction prohibition measures in accordance with instructions issued by the Executive Office or other competent authorities relating to Targeted Financial Sanctions.
Article 29(1)-2Wire Transfers
Intermediary Financial Institutions must ensure that all originator and beneficiary information accompanies international Wire Transfers they process.
Article 29(2)-2Wire Transfers
Where technical limitations prevent originator/beneficiary information from remaining with a Wire Transfer converted to a domestic transfer, the Intermediary Financial Institution must retain a record of all information received from the originating institution or foreign intermediary, per Article 25.
Article 29(3)-2Wire Transfers
Intermediary Financial Institutions must take reasonable and immediate measures to identify international Wire Transfers lacking required originator/beneficiary information, and establish risk-based policies/procedures to decide whether to execute, suspend or reject such transfers, plus follow-up actions.
Article 30(1)-2Wire Transfers
Beneficiary Financial Institutions must take Reasonable Measures to identify international Wire Transfers lacking required originator/beneficiary information, such as monitoring during or after execution.
Article 30(2)-2Wire Transfers
Beneficiary Financial Institutions must verify the identity of the beneficiary of international Wire Transfers equal to or exceeding AED 3,500, where such identity has not been previously verified.
Article 30(3)Wire Transfers
Beneficiary Financial Institutions must establish risk-based policies and procedures to determine when to execute, reject, or suspend Wire Transfers lacking required information, and the appropriate follow-up actions.
Article 30(4)Wire Transfers
Beneficiary Financial Institutions must retain all information collected in respect of the originator and beneficiary in accordance with Article 25.
Article 31(1)Wire Transfers
Money or Value Transfer Service Providers must comply with all requirements in Articles 28, 29 and 30, whether conducting activities directly or through agents.
Article 31(2)(a)Wire Transfers
Where an MVTS provider acts as both originator (from the State) and recipient (in another State), it must collect all information on the originator and beneficiary to determine whether to submit a Suspicious Transaction Report.
Article 31(2)(b)Wire Transfers
Where the MVTS provider decides to submit a Suspicious Transaction Report, it must be submitted to the Financial Intelligence Unit of the concerned State together with all relevant information.
Article 32-2Financial Groups
Financial Groups must implement group-wide anti-crime programs applicable to all majority-owned branches and subsidiaries, in addition to the Article 21 requirements.
Article 32(1)Financial Groups
Group-wide programs must include policies and procedures for the exchange of information required for CDD and crime risk management purposes.
Article 32(2)Financial Groups
Groups must provide information on customers, accounts and transactions from branches/subsidiaries to group-level compliance/audit/AML-CFT officers when necessary for combating Crime, including STR-related information/analysis, and make it available to branches/subsidiaries where appropriate and proportionate.
Article 32(3)Financial Groups
Groups must provide adequate safeguards relating to confidentiality, non-tipping-off/notification, and the use of exchanged information.
Article 33(1)Financial Groups
Financial Institutions must ensure their foreign branches/subsidiaries (majority interest) apply combating-Crime measures consistent with the Decree-Law/Resolution, where minimum host-country requirements are less stringent, to the extent permitted by host-country law.
Article 33(2)Financial Groups
Where the host State does not permit proper implementation of combating-Crime measures, Financial Institutions must take additional measures to manage/mitigate risk, notify the Supervisory Authority, and comply with its instructions.
Article 36(4)Obligations Specific to Virtual Asset Service Providers and the Scope of Their Application to Financial Institutions
The originator/beneficiary information requirements set out in Article 36(1)-(2) (obtaining, retaining and transmitting accurate originator/beneficiary data, and making it available to authorities on request) apply to Financial Institutions where they send or receive Virtual Asset Transfers on behalf of a customer.
Article 42(1)Prohibition of Invoking Bank or Professional Secrecy, or Contractual Liability
Banking secrecy, professional secrecy or contractual liability may not be invoked to prevent the exchange of information between Financial Institutions where that exchange relates to reliance on third parties (Article 20), correspondent banking relationships (Article 26), or Wire Transfers (Articles 28-31).
Article 43(1)Access to Information
Financial Institutions/DNFBPs/VASPs holding basic company information and Beneficial Owner information must make it available so that Concerned Authorities (Public Prosecution, Law Enforcement Authorities, the Unit) can obtain it as swiftly and effectively as possible.
Article 46(1)Competences of the Unit
Financial Institutions, DNFBPs and Virtual Asset Service Providers must submit Suspicious Transaction Reports (STRs) to the Financial Intelligence Unit using the report forms approved by the Unit.
Article 46(2)Competences of the Unit
FIs, DNFBPs and VASPs must provide the Unit with any additional information or documents relating to reports/information already submitted, or any other information the Unit deems necessary, within the timeframe and manner determined by the Unit.
Article 49(4)Supervisory Authority over Financial Institutions, DNFBPs, and Virtual Asset Service Providers
FIs, DNFBPs and VASPs must comply with the instructions, regulations and forms relating to Crime combating that their Supervisory Authority issues.
Article 49(5)Supervisory Authority over Financial Institutions, DNFBPs, and Virtual Asset Service Providers
FIs, DNFBPs and VASPs must provide the Supervisory Authority with information relating to implementation of the policies, procedures and controls required to verify compliance with the Decree-Law, this Resolution and other Crime-combating legislation, upon request.
Article 49(9)Supervisory Authority over Financial Institutions, DNFBPs, and Virtual Asset Service Providers
FIs, DNFBPs and VASPs are subject to risk-based off-site and on-site supervisory inspections and must provide any information the Supervisory Authority deems necessary for that purpose.
Article 49(11)Supervisory Authority over Financial Institutions, DNFBPs, and Virtual Asset Service Providers
FIs, DNFBPs and VASPs must fully and immediately comply with instructions issued by the Executive Office (or other competent authorities) regarding Targeted Financial Sanctions; the Supervisory Authority verifies this through on-site visits and continuous follow-up and may impose effective, proportionate and dissuasive administrative penalties for violations or non-compliance.
Article 49(12)Supervisory Authority over Financial Institutions, DNFBPs, and Virtual Asset Service Providers
FIs, DNFBPs and VASPs must adopt and implement the controls, procedures and measures prescribed under the Decree-Law and this Resolution, and apply them to their foreign branches and majority-owned subsidiaries to the extent permitted by host-country law.
Article 49(13)Supervisory Authority over Financial Institutions, DNFBPs, and Virtual Asset Service Providers
Where host-country law does not permit proper implementation of prescribed group AML/CFT controls, Financial Groups must apply appropriate additional measures to manage the resulting Money Laundering/Terrorist Financing risks; the Supervisory Authority may impose further controls or require closure of the foreign operation if the additional measures are insufficient.
Article 49(16)Supervisory Authority over Financial Institutions, DNFBPs, and Virtual Asset Service Providers
FIs, DNFBPs and VASPs must be notified of, and comply with, National Committee decisions on (a) Enhanced Due Diligence measures and countermeasures, (b) concerns about AML/CFT/CPF deficiencies in other countries, and (c) any other National Committee decisions.
Article 49(18)Supervisory Authority over Financial Institutions, DNFBPs, and Virtual Asset Service Providers
FIs and DNFBPs must obtain the Supervisory Authority's prior approval before appointing their Compliance Officer, who is included on the Supervisory Authority's updated list of Compliance Officers.
Article 51(4)Provisional Measures
On being notified by the Unit of a Chief-of-Unit freezing order (issued without prior notice for up to 30 days) covering funds suspected of being linked to a Crime, the relevant FI, DNFBP or VASP must implement the freezing order.
Article 51(7)Provisional Measures
FIs, DNFBPs and VASPs holding funds frozen under a Unit freezing order must notify the fund owner of the freezing order and its issuing authority, request documents proving the integrity of the transaction and the legitimacy of the source of funds, and refer that information to the Unit for appropriate action.
Article 51(8)Provisional Measures
FIs, DNFBPs and VASPs must lift a freezing order once it is revoked by the Chief of the Unit, or once the applicable period (30 days, or an extended period) expires without further extension.
Article 54(2)Provisional Measures
Financial Institutions and Virtual Asset Service Providers must transfer funds frozen pursuant to competent authorities' decisions into interest-bearing or profit-generating deposit accounts at prevailing market rates.
Article 54(4)Provisional Measures
Frozen funds, together with any accrued interest and profits, must be returned to the owner when the freezing order is lifted by the competent authorities.
Article 54(5)Provisional Measures
FIs, DNFBPs and VASPs must not dispose of seized or frozen funds under any circumstances, including to settle prior obligations, unless the Supervisory Authority coordinates to obtain authorization from the Public Prosecution or the competent court.
Article 55(4)Investigation Procedures
FIs and DNFBPs may not have information, records or account access withheld from the Public Prosecution or Law Enforcement Authorities on the ground of banking or professional secrecy where lawfully required for the detection of the Crime or its perpetrators.
Article 66(2)International Judicial Cooperation
In executing international judicial cooperation requests, competent judicial authorities may order the provision of records held by Financial Institutions, DNFBPs, VASPs or Non-Profit Organizations; the holder must provide such records when so ordered.
Article 7(4)Lifting Freezing and Other Measures in the Case of False Positives on Local Lists
Where the Council accepts a false-positive request and the Office instructs the entity where the funds are frozen (and Law Enforcement Authorities and entities concerned with Other Measures) to lift the actions taken, the addressed entity must immediately execute the decision.
Article 15(1)-2Freezing Funds As per the Sanctions List & Local Lists
Any person (including FIs and DNFBPs) must, Without Delay (within 24 hours of the listing decision) and without prior notice to the Listed Person, freeze funds identified on the Sanctions List or Local Lists, covering funds owned or controlled wholly or jointly, directly or indirectly, by the Listed Person or by persons/organizations acting on their behalf or at their direction, as well as funds derived or generated from such funds; the measure is not limited to funds usable for a specific terro
Article 15(2)-2Freezing Funds As per the Sanctions List & Local Lists
Any person who takes a freezing measure must notify the Office of that measure within five business days of the date of the freezing.
Article 15(3)Freezing Funds As per the Sanctions List & Local Lists
No person shall make funds available, or provide financial or other related services (in whole or in part, directly or indirectly), to a Listed Person or related persons/entities, except upon authorization from the Office in coordination with the Council, the UN Security Council or the relevant Sanctions Committee, and in line with Cabinet decisions on Local Lists or Relevant UNSCRs.
Article 15(4)Freezing Funds As per the Sanctions List & Local Lists
When implementing any freezing measure, the rights of bona fide third parties must be taken into account.
Article 16(1)Additions to Frozen Accounts (Interest, Profits and Other Payments under UNSCRs 1718 & 2231)
Where interest, profits or other payments due under contracts/obligations that arose before an account became subject to freezing under UNSCR 1718 (2006) or 2231 (2015) are credited to that frozen account, such additions must be immediately frozen and reported to the Office.
Article 18(4)Lifting the Freezing of Funds & Other Measures Taken in Cases of False Positives on the Sanctions List
Where the Office approves a request to lift freezing/other measures taken due to a false positive on the Sanctions List, it communicates the decision to the entity where the funds are frozen, Law Enforcement Authorities and concerned agencies; the addressed organization must immediately execute the decision to lift the freeze and other measures.
Article 19(4)Permission to Use Funds Frozen as Per the Sanctions List
Where the Office approves a Listed Person's request to access funds frozen under the Sanctions List (for necessary/basic expenses, professional fees, or certain lien/judgment-related purposes under sub-paragraphs a, b and d) and the Sanctions Committee does not object or issue a rejection within five business days, the entity holding the frozen funds must be notified in writing and must implement the unfreezing decision immediately, and must notify the Office of the actions taken.
Article 21(1)-2Obligations of Financial Institutions and DNFBPs
FIs and DNFBPs must register on the Office's website to receive notifications of new listing, re-listing, updating, or de-listing decisions issued by the UN Security Council, the Sanctions Committee, or the Cabinet.
Article 21(2)-2Obligations of Financial Institutions and DNFBPs
FIs and DNFBPs must regularly screen their customer databases, transactions and related parties against the UN Sanctions List and Local Lists, and immediately re-screen upon any changes to those lists, covering customer databases, transaction parties, potential customers, beneficial owners, and persons/organizations with a direct or indirect relationship with the institution.
Article 21(2)(f)Obligations of Financial Institutions and DNFBPs
FIs and DNFBPs must continuously search their customer database before conducting any transaction or entering into a serious business relationship with any person, to ensure that person is not listed on the Sanctions List or Local Lists.
Article 21(3)-2Obligations of Financial Institutions and DNFBPs
FIs and DNFBPs must implement freezing measures without delay and without prior notice to the Listed Person, immediately when a match is found through the screening process.
Article 21(4)-2Obligations of Financial Institutions and DNFBPs
FIs and DNFBPs must implement decisions to lift freezing measures without delay, pursuant to Relevant UNSCRs or Cabinet decisions regarding Local Lists.
Article 21(5)(a)Obligations of Financial Institutions and DNFBPs
FIs and DNFBPs must immediately notify the Supervisory Authority of funds identified and actions taken as required by Relevant UNSCRs or Cabinet decisions on Local Lists, including attempted transactions.
Article 21(5)(b)Obligations of Financial Institutions and DNFBPs
FIs and DNFBPs must immediately notify the Supervisory Authority upon detecting any match with listed persons or entities, providing details of the match data and actions taken, including attempted transactions.
Article 21(5)(c)Obligations of Financial Institutions and DNFBPs
FIs and DNFBPs must immediately notify the Supervisory Authority if it is found that one of its previous customers or any occasional customer it dealt with is listed on the Sanctions List or Local Lists.
Article 21(5)(d)Obligations of Financial Institutions and DNFBPs
FIs and DNFBPs must immediately notify the Supervisory Authority if they suspect that one of their current or former customers, or a person with whom they have a business relationship, is listed or has a direct or indirect relationship with the Listed Person.
Article 21(5)(e)Obligations of Financial Institutions and DNFBPs
FIs and DNFBPs must immediately notify the Supervisory Authority where no action has been taken due to a suspected false positive that cannot be dismissed using available or accessible information.
Article 21(5)(f)Obligations of Financial Institutions and DNFBPs
FIs and DNFBPs must immediately notify the Supervisory Authority of information relating to funds that have been unfrozen, including their status, nature, value, and the measures taken in respect thereof.
Article 21(6)-2Obligations of Financial Institutions and DNFBPs
FIs and DNFBPs must establish and effectively implement internal controls and procedures to ensure compliance with the obligations arising from this Decision.
Article 21(7)Obligations of Financial Institutions and DNFBPs
FIs and DNFBPs must establish and implement policies and procedures that prohibit staff from directly or indirectly informing the customer or any third party that freezing or Other Measures shall be implemented.
Article 21(8)Obligations of Financial Institutions and DNFBPs
FIs and DNFBPs must cooperate with the Office and the Supervisory Authority in verifying the accuracy of submitted information.
Article 23(1)-2General Provisions
Any person who, due to the nature of their work, has access to or becomes aware of any information provided or exchanged pursuant to this Decision must not disclose that information in any form, unless for the purposes of implementing the Decision.
Article 23(2)-2General Provisions
A person who, in good faith, freezes funds, denies disposal thereof, refuses to provide financial services relating thereto, or declines to perform any other obligation in compliance with this Decision, is exempt from any damages or claims resulting from such actions -- underscoring the need to act, and be able to demonstrate acting, in good faith.
MoE AML/CFT's 208 indexed articles break down by obligation type as follows.
Compliance — 96 articles
MLRO — 19 articles
Senior Management/Governing Body — 17 articles
Compliance/Legal — 9 articles
MLRO/Compliance — 9 articles
Compliance/MLRO — 9 articles
MoE AML/CFT spans the following regulatory topics, as tagged by Lexara.
aml
cft
proliferation financing
dnfbp
kyc
cdd
str
goaml
sanctions
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What is Federal Decree-Law No. 10 of 2025?
Federal Decree-Law No. 10 of 2025 is issued by the Ministry of Economy — AML/CFT & Commercial Supervision and has applied since 1 January 2025. It has 208 articles across 3 chapters.
What does MoE AML/CFT cover?
It is organised into: Federal Decree by Law No. 10 of 2025; Cabinet Resolution No. 134 of 2025 (Executive Regulations); Cabinet Decision No. 74 of 2020.
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The Ministry of Economy — AML/CFT & Commercial Supervision. Always check the authority's official publication for the binding text.
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