In this episode of The Riffle, we examine the 2026 amendments to the Dubai Financial Services Authority’s Anti-Money Laundering, Counter-Terrorist Financing and Sanctions Module (AML), enacted under Rule-Making Instrument No. 435 of 2026.
The discussion explores the alignment of the DIFC regulatory framework with Federal Law No. 10 of 2025 and Cabinet Resolution No. 134 of 2025, effective 2 March 2026, and the resulting expansion of supervisory expectations for Authorised Firms and DNFBPs.
We analyse the formal integration of proliferation financing into the AML regime, enhanced customer due diligence requirements for natural and legal persons, the risk-based approach to beneficial ownership without fixed thresholds, and strengthened governance responsibilities for senior management and MLROs.
Particular attention is given to the explicit application of Federal AML obligations to Virtual Asset Service Providers (VASPs), enhanced sanctions screening requirements, SAR reporting obligations to the Financial Intelligence Unit, and the DFSA’s reinforced administrative penalty powers within the DIFC.
A concise overview for boards, senior management, MLROs, compliance officers, legal teams, VASPs, and regulated entities seeking clarity on the heightened AML and financial crime compliance expectations under the revised framework.
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