AML Obligations for Real Estate in the UAE: A DNFBP Guide

Regulatory Framework

The UAE’s AML/CFT regime for designated non-financial businesses and professions is primarily governed by Federal Decree-Law No. 10 of 2025 on Anti-Money Laundering and Combating the Financing of Terrorism, which replaced Federal Decree-Law No. 20 of 2018, together with its implementing decisions.

The Cabinet Decision sets out specific requirements for DNFBPs operating in various sectors, including real estate. The regulation requires real estate agents, developers, and brokers to implement measures to prevent their businesses from being used for money laundering or terrorist financing purposes.

Supervisory responsibility for real estate DNFBPs is shared between federal authorities and emirate-level regulators. The Securities and Commodities Authority (SCA) plays a role in supervising certain real estate activities, while emirate-level authorities oversee other aspects of real estate operations.

The UAE Financial Intelligence Unit (UAEFIP) receives STRs from DNFBPs and coordinates with law enforcement on financial intelligence matters.

Customer Due Diligence Obligations

CDD measures include:

Identification: Obtaining sufficient information to identify the customer. For individuals, this includes full name, date of birth, nationality, and address. For legal entities, this includes the company name, registration number, legal form, and registered address.

Verification: Verifying the customer’s identity using reliable and independent documents. For companies, this includes verifying the identity of directors and beneficial owners.

Beneficial ownership: Identifying the beneficial owner, defined as any natural person who ultimately owns or controls 25 percent or more of the customer entity, or who exercises significant control over the entity. Where property is held through multiple layers of ownership, the beneficial owner is the individual at the top of the chain.

Source of funds: Understanding the source of funds for the transaction, including the origin of the money being used to purchase the property.

Source of wealth: For higher-risk customers, understanding the source of wealth, which refers to the origin of the customer’s overall financial standing.

Ongoing monitoring: Maintaining awareness of customer activity and conducting periodic reviews to ensure the risk rating remains appropriate.

Record Keeping

Real estate DNFBPs must maintain records of all CDD information, including copies of identification documents, for at least five years following the completion of the transaction or the end of the business relationship. These records must be made available to the UAEFIP and other competent authorities upon request.

STR Filing

Where a real estate DNFBP knows, suspects, or has reasonable grounds to suspect that a transaction or attempted transaction involves proceeds of crime or is related to terrorist financing, an STR must be filed with the UAEFIP promptly.

The tipping-off prohibition applies: DNFBPs must not disclose to the customer or third parties that an STR has been or may be filed. This prohibition is subject to criminal penalties.

Red Flags for UAE Property Transactions

The nature of the UAE real estate market creates specific red flags that practitioners should be alert to. These include:

Cash transactions: Large cash payments for property purchases, particularly where the amount approaches or exceeds reporting thresholds, may indicate an attempt to avoid the financial system.

Off-plan property: Purchases of off-plan property, particularly in developments where the finished property may differ significantly from the plan, may be used to inflate prices or move funds through the development sector.

Shell company purchases: Property acquired through shell companies, particularly where the beneficial ownership is obscured through multiple layers or jurisdictions, may indicate attempts to conceal the true owner.

High-value transactions: Transactions significantly above market value may indicate attempts to launder funds through the property market.

Rapid resale: Property purchased and quickly resold at a higher price may indicate attempts to create the appearance of legitimate transaction activity.

Unusual payment patterns: Payments from multiple sources, payments from third parties without apparent connection to the customer, or requests to structure payments to avoid reporting thresholds.

PEP involvement: Transactions involving politically exposed persons, including UAE government officials and their family members or close associates, require enhanced scrutiny.

International transfers: Large international wire transfers, particularly from jurisdictions with elevated corruption or money laundering risk, require additional due diligence.

Beneficial Ownership Challenges

Identifying beneficial owners in real estate transactions can be challenging, particularly where property is held through complex structures such as companies, trusts, or foundations. The UAE has taken steps to improve beneficial ownership transparency, but challenges remain.

Practitioners should:

Training and Awareness

Real estate DNFBPs must ensure that staff involved in property transactions receive appropriate training on AML/CFT obligations. Training should cover the regulatory requirements, how to identify suspicious activity, and the STR filing process.

Training records should be maintained and refreshed periodically as the regulatory environment evolves.

Implications for Compliance Leaders

The UAE’s real estate sector faces ongoing supervisory attention to AML/CFT compliance. The FATF’s 2020 mutual evaluation of the UAE identified the Dubai property market as an area requiring improved supervision and enforcement.

For real estate organisations, this means building compliance programmes that go beyond minimum documentation requirements. Effective CDD, transaction monitoring where applicable, and a clear escalation process for suspicious activity are essential.

Nexiant supports real estate organisations in the UAE with AI-assisted screening and compliance solutions. Contact our team to discuss your requirements.

This article was accurate at the time of publication in August 2026 and is intended for general informational purposes only. It does not constitute legal, regulatory or compliance advice. Organisations should seek qualified professional guidance in relation to their specific obligations.