Legal Foundations for Startups in the UAE: Building for Growth from Day One
Key Highlights of the Core Changes Introduced by UAE AML/CFT Law No. 10 of 2025 The UAE has introduced a significantly strengthened Anti-Money Laundering and Counter-Terrorist Financing framework through Federal Decree-Law No. 10 of 2025, which repeals and replaces the previous AML legislation issued in 2018. The new law materially expands regulatory oversight, enforcement powers, and penalty thresholds, while introducing new criminal classifications, most notably Proliferation Financing. The law came into effect on 14 October 2025. Its Executive Regulations, issued under Cabinet Resolution No. 134 of 2025, will apply from 14 December 2025. Among the most notable developments are: -Explicit regulation of Virtual Assets and Virtual Asset Service Providers (VASPs), including licensing, transaction monitoring, reporting obligations, and enhanced oversight of cryptographic and blockchain-based technologies. -Increased regulatory scrutiny of Beneficial Ownership disclosures, Suspicious Transaction Reporting (STR), sanctions screening, and enterprise-wide risk assessments. -Expanded powers of the Financial Intelligence Unit (FIU), including broader authority to impose preventive freezing measures. -Significantly higher administrative and criminal penalties, with corporate fines reaching up to AED 100 million, alongside potential licence suspension or dissolution in cases of serious or repeated non-compliance. -Entities subject to the AML/CFT regime are expected to review and upgrade their governance structures, internal controls, and compliance systems without delay. Federal Decree-Law No. 10 of 2025: A Fundamental Shift in the UAE AML/CFT Framework Federal Decree-Law No. 10 of 2025 represents the most comprehensive reform of the UAE’s AML/CFT framework to date. Effective from 14 October 2025, it repeals Federal Law No. 20 of 2018, following interim amendments introduced in 2024. The new law does not merely consolidate existing obligations; it fundamentally recalibrates how compliance is assessed, enforced, and penalised. While the legislation is now in force, existing Executive Regulations, ministerial resolutions, and regulatory circulars remain applicable until formally replaced. In this regard, Cabinet Resolution No. 10 of 2019 will be repealed by Cabinet Resolution No. 134 of 2025, which sets out the new Executive Regulations on combating money laundering, terrorist financing, and the financing of the proliferation of weapons, effective 14 December 2025. During this transitional period, regulated entities must continue to comply with existing instruments while preparing their systems, policies, and controls for the enhanced obligations introduced under the new regime. Scope and Regulatory Intent of the New AML Law Through Federal Decree-Law No. 10 of 2025, the UAE has reinforced its commitment to maintaining a robust, internationally aligned financial crime framework. The law expands the scope of criminalised conduct, strengthens supervisory authority, and directly addresses risks arising from digital assets, cross-border transactions, and evolving financial technologies. The introduction of Proliferation Financing as a standalone offence reflects alignment with international standards and underscores the UAE’s focus on addressing emerging global financial crime risks. Any entity engaged in regulated financial or designated non-financial activities must now meet higher compliance standards, including enhanced due diligence, improved monitoring and reporting, and strengthened internal risk governance. Practical Implications for Businesses The new AML/CFT law materially increases regulatory expectations for boards, senior management, and compliance functions. Demonstrable compliance, effective risk assessment, and properly documented internal controls will be critical in mitigating enforcement exposure. Failure to adapt to the new framework may result not only in substantial financial penalties but also in regulatory restrictions that directly impact business continuity. At AT-LAW, we advise financial institutions, DNFBPs, virtual asset businesses, and corporate groups on navigating complex regulatory transitions. The implementation of Federal Decree-Law No. 10 of 2025 requires a structured, legally sound approach that aligns regulatory obligations with operational realities. Early legal assessment, targeted gap analysis, and governance-focused compliance planning are essential to managing risk under the new AML/CFT framework.
Compliance in the Shipping Sector: The Importance of Departmental Training in Ship Management Companies The shipping sector is one of the most heavily regulated industries globally. Ship management companies operate at the intersection of international conventions, flag state regulations, port state controls, and local legal frameworks. In this complex regulatory environment, compliance is not merely a legal obligation—it is a strategic necessity. Effective compliance depends not only on policies and procedures, but on continuous, structured training across all departments of a ship management company. The Regulatory Landscape Facing Ship Management Companies Ship management companies must navigate an extensive web of regulations, including: -International Maritime Organization (IMO) conventions such as SOLAS, MARPOL, ISM Code, ISPS Code, and STCW -Flag state and port state control requirements -Environmental compliance, including emissions, ballast water management, and waste disposal -Sanctions, trade controls, and anti-bribery and corruption laws -Seafarer employment laws, occupational health and safety, and crew welfare obligations Non-compliance can result in vessel detentions, fines, loss of insurance coverage, termination of charter parties, reputational harm, and potential civil or criminal liability for both corporate entities and senior management. Why Compliance Training Must Be Department-Wide In many ship management companies, compliance is mistakenly treated as the sole responsibility of the legal or compliance department. In practice, regulatory obligations are embedded in day-to-day operational decisions across the entire organization. Department-specific training is therefore essential. Technical and Marine Operations Departments These teams are directly responsible for vessel safety, maintenance, and seaworthiness. Training must focus on: -ISM Code implementation and documentation -Safety management systems (SMS) -Accident reporting and investigation -Port state control preparedness A lack of understanding in this area can expose the company to serious safety incidents and regulatory enforcement actions. Crewing and HR Departments Crewing departments play a critical role in compliance with maritime labor laws. Training should address: -STCW certification and competency requirements -Maritime Labour Convention (MLC) compliance -Crew contracts, wages, repatriation, and welfare obligations -Disciplinary procedures and dispute management -Improper handling of crew matters can lead to detentions, claims, and reputational damage. Commercial and Chartering Teams -Commercial decisions often carry hidden compliance risks. Training should cover: -Sanctions and trade restrictions -Charter party compliance obligations -Anti-bribery and corruption risks -Due diligence on counterparties Failure in this area may expose the company to regulatory investigations and contractual disputes. Finance and Procurement Departments These departments must be trained on: -Sanctions screening and payment compliance -Anti-money laundering (AML) principles -Contractual risk allocation -Audit readiness and record-keeping -Financial non-compliance can trigger regulatory penalties and banking restrictions. -Legal Risk Management Through Training From a legal perspective, structured compliance training demonstrates that a ship management company has taken reasonable steps to prevent violations. This is a critical factor in mitigating liability in the event of regulatory investigations, claims, or disputes. Well-documented training programs also support internal governance, enhance audit outcomes, and strengthen the company’s defense position when facing enforcement actions. The Role of Legal Advisors in Compliance Training Legal advisors play a key role in designing and delivering effective compliance training tailored to the operational realities of ship management companies. This includes: Translating legal requirements into practical, department-specific guidance Identifying regulatory gaps and risk exposure Advising on best practices aligned with international standards Supporting incident response, investigations, and regulatory communications At AT-LAW, we work closely with shipping and maritime clients to develop compliance frameworks and training programs that are both legally robust and operationally practical.
Key Highlights of the Core Changes Introduced by UAE AML/CFT Law No. 10 of 2025 The UAE has introduced a significantly strengthened Anti-Money Laundering and Counter-Terrorist Financing framework through Federal Decree-Law No. 10 of 2025, which repeals and replaces the previous AML legislation issued in 2018. The new law materially expands regulatory oversight, enforcement powers, and penalty thresholds, while introducing new criminal classifications, most notably Proliferation Financing. The law came into effect on 14 October 2025. Its Executive Regulations, issued under Cabinet Resolution No. 134 of 2025, will apply from 14 December 2025. Among the most notable developments are: -Explicit regulation of Virtual Assets and Virtual Asset Service Providers (VASPs), including licensing, transaction monitoring, reporting obligations, and enhanced oversight of cryptographic and blockchain-based technologies. -Increased regulatory scrutiny of Beneficial Ownership disclosures, Suspicious Transaction Reporting (STR), sanctions screening, and enterprise-wide risk assessments. -Expanded powers of the Financial Intelligence Unit (FIU), including broader authority to impose preventive freezing measures. -Significantly higher administrative and criminal penalties, with corporate fines reaching up to AED 100 million, alongside potential licence suspension or dissolution in cases of serious or repeated non-compliance. -Entities subject to the AML/CFT regime are expected to review and upgrade their governance structures, internal controls, and compliance systems without delay. Federal Decree-Law No. 10 of 2025: A Fundamental Shift in the UAE AML/CFT Framework Federal Decree-Law No. 10 of 2025 represents the most comprehensive reform of the UAE’s AML/CFT framework to date. Effective from 14 October 2025, it repeals Federal Law No. 20 of 2018, following interim amendments introduced in 2024. The new law does not merely consolidate existing obligations; it fundamentally recalibrates how compliance is assessed, enforced, and penalised. While the legislation is now in force, existing Executive Regulations, ministerial resolutions, and regulatory circulars remain applicable until formally replaced. In this regard, Cabinet Resolution No. 10 of 2019 will be repealed by Cabinet Resolution No. 134 of 2025, which sets out the new Executive Regulations on combating money laundering, terrorist financing, and the financing of the proliferation of weapons, effective 14 December 2025. During this transitional period, regulated entities must continue to comply with existing instruments while preparing their systems, policies, and controls for the enhanced obligations introduced under the new regime. Scope and Regulatory Intent of the New AML Law Through Federal Decree-Law No. 10 of 2025, the UAE has reinforced its commitment to maintaining a robust, internationally aligned financial crime framework. The law expands the scope of criminalised conduct, strengthens supervisory authority, and directly addresses risks arising from digital assets, cross-border transactions, and evolving financial technologies. The introduction of Proliferation Financing as a standalone offence reflects alignment with international standards and underscores the UAE’s focus on addressing emerging global financial crime risks. Any entity engaged in regulated financial or designated non-financial activities must now meet higher compliance standards, including enhanced due diligence, improved monitoring and reporting, and strengthened internal risk governance. Practical Implications for Businesses The new AML/CFT law materially increases regulatory expectations for boards, senior management, and compliance functions. Demonstrable compliance, effective risk assessment, and properly documented internal controls will be critical in mitigating enforcement exposure. Failure to adapt to the new framework may result not only in substantial financial penalties but also in regulatory restrictions that directly impact business continuity. At AT-LAW, we advise financial institutions, DNFBPs, virtual asset businesses, and corporate groups on navigating complex regulatory transitions. The implementation of Federal Decree-Law No. 10 of 2025 requires a structured, legally sound approach that aligns regulatory obligations with operational realities. Early legal assessment, targeted gap analysis, and governance-focused compliance planning are essential to managing risk under the new AML/CFT framework.
Compliance in the Shipping Sector: The Importance of Departmental Training in Ship Management Companies The shipping sector is one of the most heavily regulated industries globally. Ship management companies operate at the intersection of international conventions, flag state regulations, port state controls, and local legal frameworks. In this complex regulatory environment, compliance is not merely a legal obligation—it is a strategic necessity. Effective compliance depends not only on policies and procedures, but on continuous, structured training across all departments of a ship management company. The Regulatory Landscape Facing Ship Management Companies Ship management companies must navigate an extensive web of regulations, including: -International Maritime Organization (IMO) conventions such as SOLAS, MARPOL, ISM Code, ISPS Code, and STCW -Flag state and port state control requirements -Environmental compliance, including emissions, ballast water management, and waste disposal -Sanctions, trade controls, and anti-bribery and corruption laws -Seafarer employment laws, occupational health and safety, and crew welfare obligations Non-compliance can result in vessel detentions, fines, loss of insurance coverage, termination of charter parties, reputational harm, and potential civil or criminal liability for both corporate entities and senior management. Why Compliance Training Must Be Department-Wide In many ship management companies, compliance is mistakenly treated as the sole responsibility of the legal or compliance department. In practice, regulatory obligations are embedded in day-to-day operational decisions across the entire organization. Department-specific training is therefore essential. Technical and Marine Operations Departments These teams are directly responsible for vessel safety, maintenance, and seaworthiness. Training must focus on: -ISM Code implementation and documentation -Safety management systems (SMS) -Accident reporting and investigation -Port state control preparedness A lack of understanding in this area can expose the company to serious safety incidents and regulatory enforcement actions. Crewing and HR Departments Crewing departments play a critical role in compliance with maritime labor laws. Training should address: -STCW certification and competency requirements -Maritime Labour Convention (MLC) compliance -Crew contracts, wages, repatriation, and welfare obligations -Disciplinary procedures and dispute management -Improper handling of crew matters can lead to detentions, claims, and reputational damage. Commercial and Chartering Teams -Commercial decisions often carry hidden compliance risks. Training should cover: -Sanctions and trade restrictions -Charter party compliance obligations -Anti-bribery and corruption risks -Due diligence on counterparties Failure in this area may expose the company to regulatory investigations and contractual disputes. Finance and Procurement Departments These departments must be trained on: -Sanctions screening and payment compliance -Anti-money laundering (AML) principles -Contractual risk allocation -Audit readiness and record-keeping -Financial non-compliance can trigger regulatory penalties and banking restrictions. -Legal Risk Management Through Training From a legal perspective, structured compliance training demonstrates that a ship management company has taken reasonable steps to prevent violations. This is a critical factor in mitigating liability in the event of regulatory investigations, claims, or disputes. Well-documented training programs also support internal governance, enhance audit outcomes, and strengthen the company’s defense position when facing enforcement actions. The Role of Legal Advisors in Compliance Training Legal advisors play a key role in designing and delivering effective compliance training tailored to the operational realities of ship management companies. This includes: Translating legal requirements into practical, department-specific guidance Identifying regulatory gaps and risk exposure Advising on best practices aligned with international standards Supporting incident response, investigations, and regulatory communications At AT-LAW, we work closely with shipping and maritime clients to develop compliance frameworks and training programs that are both legally robust and operationally practical.