Proliferation Financing Frameworks for UAE DNFBPs

The UAE’s AML/CFT regime now treats proliferation financing (PF) as a risk in its own right, alongside money laundering (ML) and terrorist financing (TF).

Federal Decree-Law No. 10 of 2025, in force since 14 October 2025, replaced the 2018 AML law and brought PF squarely within the framework. For DNFBPs, the practical question is whether existing compliance programmes genuinely address PF risk, or simply refer to it.

In April 2026, the Central Bank of the UAE issued updated AML/CFT/CPF guidance, including guidance on PF risk. The guidance is addressed to licensed financial institutions and registered hawala providers; however, practitioner commentary suggests that DNFBPs supervised by the Ministry of Economy may be assessed against similar PF expectations during inspections. Businesses should confirm the requirements applicable to them directly with their Supervisory Authority.

What should a PF framework cover? In practice, it can be structured around five areas:

1. Risk Assessment

Assess and document PF risks across customers, products and services, geographies and delivery channels.

2. Customer and Beneficial Ownership Due Diligence

Verify customer identity and beneficial ownership at onboarding, and ensure the information remains accurate and up to date.

3. Screening

Screen customers and transactions against the UAE Local Terrorist List and the UN Consolidated List, as well as any other lists required by the business’s risk profile.

4. Escalation and Reporting

Escalate potential matches to the Compliance Officer, who determines the action required, including any reporting through goAML.

5. Independent Review and Continuous Updating

Periodically review the effectiveness of the framework, maintain appropriate records, and update policies and procedures as legislation and regulatory expectations evolve.

PF should not be treated as a standalone compliance exercise. It should be integrated into the organisation’s broader risk-based AML/CFT/CPF framework.

If your AML manual still refers only to the 2018 legislation, it should be reviewed and updated against the current regulatory framework.

At Make My Business, we work with clients to develop practical AML frameworks and monitor UAE legislation and regulatory guidance, helping ensure their compliance programmes remain aligned with evolving requirements.

For support with your AML/CFT/CPF framework, policies, risk assessment or regulatory compliance, contact us at info@makemy-business.com , +91 91200 20203 or +971 56 787 1327 .

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