New UAE‑UK AML strategy zeroes in on crypto crime and cross‑border asset recovery efforts in 2026.
- UAE and UK launch Combined Anti-Money Laundering Operational Team (CAMLOT) to target crypto-linked illicit finance networks across both jurisdictions.
- Federal Decree-Law No. 10 of 2025 updates UAE's AML framework to explicitly cover digital platforms and virtual asset crime from 2026.
- New UAE law strengthens asset tracing, freezing, and confiscation powers while enhancing mutual legal assistance and recognition of foreign confiscation orders.
- Virtual Asset Service Providers (VASPs) in UAE face tighter AML expectations under VARA, FSRA, DFSA, and SCA regulatory frameworks.
- Joint SCA-VARA framework expected early 2026 aims to harmonise virtual asset supervision and close regulatory gaps.
- UAE-UK partnership emphasises intelligence sharing, coordinated enforcement, and joint investigations targeting crypto-enabled money laundering.
UAEFIU and UK Partners Strengthen Operational Coordination
The UAE Financial Intelligence Unit (UAEFIU) and UK authorities are intensifying cross-border cooperation on anti-money laundering (AML) enforcement as crypto-related financial crime becomes a central focus for both jurisdictions in 2026. Federal Decree-Law No. 10 of 2025, which takes effect this year, expands the UAE's legal framework to explicitly address money laundering committed through electronic systems and digital platforms. The law introduces stronger mechanisms for tracing and confiscating criminal proceeds, including those linked to virtual assets, while removing previous barriers to international cooperation such as tax secrecy limitations.
Virtual Asset Service Providers (VASPs) operating in the UAE now face heightened regulatory scrutiny under frameworks administered by the Dubai Virtual Assets Regulatory Authority (VARA), the Financial Services Regulatory Authority (FSRA) in Abu Dhabi Global Market (ADGM), the Dubai Financial Services Authority (DFSA), and the Securities and Commodities Authority (SCA). Compliance expectations in 2026 reflect the convergence of domestic regulatory reforms and the demands of international partnerships, particularly the UAE-UK collaboration established in 2021 and reinforced through a series of bilateral meetings in 2025.
Strategic UAE-UK Partnership and CAMLOT Launch
The UAE-UK Partnership to Tackle Illicit Financial Flows was launched in 2021 as a bilateral platform for intelligence exchange, policy alignment, and operational collaboration between the two financial centres. The partnership is jointly led by senior representatives including the UAE's Minister of State and UK Home Office and Security leadership, with an explicit mandate to strengthen cross-border AML and counter-terrorist financing (CTF) efforts.
A key operational pillar of this partnership is the Combined Anti-Money Laundering Operational Team (CAMLOT), which held its inaugural meeting hosted by the UAEFIU. CAMLOT is designed to identify and disrupt hidden financial networks and money laundering operations spanning both jurisdictions, with a particular focus on complex, multi-jurisdictional financial structures used to fund crime globally.
Ali Faisal Ba'Alawi, Chief of the UAE Financial Intelligence Unit, described strengthened cooperation with regional and international partners as crucial in confronting money laundering, combating terrorism financing, and protecting the integrity of local and global financial systems. Adrian Searle, Director of the UK's National Economic Crime Centre, emphasised that international cooperation is key to tackling the global nature of illicit finance.
Crypto and Virtual Asset Regulatory Framework in UAE
Virtual assets in the UAE are regulated through a multi-layered framework involving the Central Bank of the UAE (CBUAE), SCA, VARA, FSRA, and DFSA. VARA, established in 2022 and expanded through 2023-2024, oversees all virtual asset activities in Dubai excluding DIFC, and has issued a standalone regulatory framework including marketing regulations for promotions and consumer communications.
FSRA in ADGM licenses exchanges as Multilateral Trading Facilities (MTFs), requires separate permissions for custody, and imposes documented prudential standards including market surveillance and client asset protection requirements. Within ADGM, virtual assets are treated as commodities rather than specified investments, but activities involving virtual assets still require FSRA licensing, and only Accepted Virtual Assets (AVAs) that meet FSRA criteria may be offered.
DFSA regulates crypto tokens through its Crypto Token Framework, which includes token admission policies, client asset rules, and updated custody standards. In mainland UAE, SCA rulebooks define virtual asset activities and impose governance, AML, and capital requirements on crypto intermediaries. A joint SCA-VARA framework expected by early 2026 aims to provide mutual recognition of VASP licenses, joint supervision, and coordinated enforcement against breaches.
Federal Decree-Law No. 10 of 2025: New AML Framework
The UAE's new AML/CTF law, Federal Decree-Law No. 10 of 2025, applicable from 2026, updates the country's legislative framework to account for digital platforms and cross-border crime. The law explicitly recognises that money laundering can be committed via electronic systems and digital platforms, broadening the legal basis for enforcement against illicit activity involving virtual assets and online financial infrastructure.
A key feature of the law is a strengthened framework for tracing, identifying, freezing, confiscating, and managing proceeds of crime, including property, funds, and other assets, while including provisions to protect bona fide third parties. The law enhances mechanisms for international cooperation in asset recovery, including mutual legal assistance and recognition or execution of foreign confiscation orders.
These asset-recovery provisions align with the UAE's commitment under international standards and the UAE-UK partnership to cooperate with foreign jurisdictions on tracing and recovering assets linked to serious and organised crime. The narrowing of previous limitations such as tax secrecy exceptions makes cross-border cooperation significantly easier.
UK AML Strategy and Economic Crime Plan
The UK's approach to AML and crypto crime within the UAE-UK partnership sits within its broader economic crime strategy, which includes enhanced regulations for virtual asset service providers and reforms under its Economic Crime Plan. The UK requires registration of crypto-asset exchange providers and custodian wallet providers with the Financial Conduct Authority (FCA) and applies the travel rule and other AML controls to virtual asset transfers.
UK Security Minister Dan Jarvis visited the UAE in February 2025 and met with UAE Minister of State Ahmed bin Ali Al-Sayegh to advance the partnership, agreeing to increase judicial cooperation and maintain continuous alignment on illicit finance. The UK government described this cooperation as strengthening both countries' roles as leaders in global efforts against illicit finance and emphasised that cross-border joint work is critical to national security.
Enhanced AML Compliance Expectations for 2026
By 2026, AML expectations for crypto firms and financial service providers in the UAE reflect the convergence of the updated federal AML law, virtual asset regulatory frameworks, and international cooperation demands. UAE compliance guidance highlights that regulated firms must implement robust governance, risk management, and AML measures, including customer due diligence (CDD), enhanced due diligence (EDD) for high-risk activities, ongoing monitoring, and timely suspicious transaction reporting to the UAEFIU.
Under VARA's regime in Dubai, VASPs must meet explicit requirements around AML systems, transaction monitoring, and screening, alongside prudential and conduct-of-business obligations. Violations are subject to administrative fines, license suspension, or revocation. FSRA-licensed entities in ADGM must implement detailed AML systems aligned with its rulebooks, including controls around market surveillance for exchanges and segregation of client assets for custodians.
DFSA's Crypto Token Framework imposes AML and sanctions compliance obligations on authorised firms dealing with crypto tokens, requiring them to assess token risks, implement controls for transfers and custody, and monitor for suspicious or high-risk behaviour. The updated AML law for 2026 emphasises that regulated entities should account for digital and virtual asset risks in their AML programmes, particularly where transactions are conducted through electronic systems or involve cross-border flows susceptible to layering and obfuscation.
Cross-Border Enforcement and Information Sharing
Bilateral meetings in 2025 confirmed that both governments intend to deepen collaboration on strategic priorities, enhance bilateral dialogue, and facilitate the exchange of best practices and information across regulatory, supervisory, law-enforcement, and judicial domains. The UAE-UK partnership explicitly includes cooperation between financial intelligence units (FIUs), law-enforcement agencies, and supervisory authorities to respond more quickly to suspicious activity.
Authorities in both countries have framed financial crime as a global problem requiring global solutions, stressing that joint operations, shared intelligence, and coordinated enforcement are central to disrupting illicit financial networks that exploit cross-border channels and emerging technologies. The partnership also aims to support legitimate bilateral trade and investment by reducing exposure to organised crime and illicit financial flows.
Implications for UAE Crypto and Financial Service Providers
For UAE-based virtual asset service providers and financial institutions with cross-border links to the UK, the combination of the 2026 UAE AML law, evolving virtual asset frameworks, and the deepened UAE-UK partnership implies tighter expectations around risk-based AML controls and scrutiny of crypto-linked flows. Firms should expect closer cross-border coordination between UK and UAE law-enforcement bodies, which may lead to more frequent requests for information, production orders, freezing instructions, and joint investigations.
Regulated entities in the UAE are likely to face heightened supervisory focus on transaction monitoring systems that can detect unusual patterns in virtual asset flows, links to high-risk jurisdictions, mixing or tumbling services, or layering techniques that obscure the trail of funds. Given the strengthened asset recovery framework and narrowing of limitations such as tax secrecy, firms may see faster escalation from suspicious transaction reporting to asset-tracing actions, freezing, and confiscation orders, particularly when cases have a UK nexus or relate to serious organised crime.
The combined effect is that UAE crypto and financial service providers operating in or with the UK must regard enhanced AML programmes, clear governance structures, and proactive law-enforcement engagement as critical to regulatory compliance and continued market access in 2026.
Further Reading
UK Government: UAE and UK strengthen cooperation on illicit financeUAE Ministry of Foreign Affairs: UAE-UK bilateral meeting on financial security
UAEFIU: Inaugural CAMLOT meeting announcement
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