Being one of the most exciting markets on earth. The UAE real estate sector is a magnet for global investment – and a symbol of visionary growth.
But this high-value, high-speed environment also creates a critical risk: money laundering.
And the UAE government is taking decisive action.
If you are a real estate broker, agent, or developer in the UAE, you are now on the front line of the nation’s financial crime defense.
The days of treating Anti-Money Laundering (AML) and Know Your Customer (KYC) as a simple “ID check” are over.
The UAE’s removal from the FATF “grey list” in February 2024 was not the end – it marked the beginning of a new era of strict enforcement.
The stakes have never been higher.
So – what exactly has changed? And are you prepared?
This post is your urgent 2025 AML compliance briefing.
The Game-Changer: Federal Decree-Law No. (10) of 2025
While you were closing deals, the legal landscape shifted beneath your feet.
The new Federal Decree-Law No. (10) of 2025 overhauls the UAE’s core Anti-Money Laundering (AML) and Counter-Terrorist Financing (CFT) framework.
The Critical Change: The Burden of Proof
Previously, a money laundering offense generally required “actual knowledge.”
Under the new law, the test is now “knew or should have known.”
That means ignorance is no longer a defense. If a broker could reasonably have known that a client or transaction was suspicious – and did nothing -the firm can be held liable.
This makes one thing absolutely clear:
Documented due diligence and professional training are now your strongest legal protection.
You Are a DNFBP — and That Means Legal Duties
Real estate companies in the UAE are classified as Designated Non-Financial Businesses and Professions (DNFBPs) under the Ministry of Economy (MOE).
This legal designation carries specific, non-negotiable compliance obligations, monitored by the MOE and the UAE Financial Intelligence Unit (FIU).
Failure to comply is not just “bad practice” — it’s a federal offense.
The Cost of Getting It Wrong
The Ministry of Economy has made enforcement a top priority.
- Administrative Fines: AED 50,000 up to AED 5 million per violation, depending on severity.
- Operational Suspension: Your trade license can be suspended or revoked.
- Criminal Liability: In serious cases, managers and compliance officers may face prosecution or imprisonment.
One missed “red flag” could erase your firm’s entire annual commission.
The 7 Pillars of Mandatory AML/KYC Compliance
Every UAE real estate firm must build its AML program on these seven legal pillars:
1️⃣ Appoint a Certified Compliance Officer
Designate a Compliance Officer (MLRO) with authority and resources to manage your AML framework, risk assessments, and reporting obligations.
2️⃣ Register on the goAML System
All DNFBPs must register on the FIU’s goAML portal – the only official system for filing AML reports and Real Estate Activity Reports (REARs).
3️⃣ Conduct Customer Due Diligence (CDD)
Before completing any transaction, you must:
- Identify and verify both buyer and seller (passport or Emirates ID)
- Identify and verify the Ultimate Beneficial Owner (UBO)
- Understand the source of funds and wealth (not just where the payment comes from, but how it was earned)
4️⃣ Perform Enhanced Due Diligence (EDD)
Apply additional scrutiny to:
- Politically Exposed Persons (PEPs)
- Clients from high-risk jurisdictions (as per FATF)
- Unusually complex or illogical structures
5️⃣ Screen Against Sanctions Lists (TFS)
Every client must be screened against Targeted Financial Sanctions (TFS) lists – including the UAE Local Terrorist List and UN Consolidated List – before onboarding.
6️⃣ File STRs or REARs Promptly
If a transaction appears suspicious (e.g., unexplained structures, last-minute name changes, large cash payments):
- File a Suspicious Transaction Report (STR) or Real Estate Activity Report (REAR) via goAML immediately.
- Do not tip off the client — this is a serious offense on its own.
7️⃣ Maintain Records for 5 Years
Keep all CDD records, transaction files, and STR/REAR reports securely for at least five years, even if the deal falls through.
Don’t Just Comply — Compete
Adilzone Is Your Dedicated AML Partner
Compliance isn’t just about avoiding penalties – it’s about building credibility and trust with investors, banks, and global partners.
At Adilzone, we help companies and professionals transform complex legal duties into a clear, streamlined, and practical system.
We don’t just consult – we build your compliance System.
Our Services for Real Estate Brokers, Developers & Agents
1. Expert AML/KYC Training
We train your team – from brokers to compliance officers – on the latest AML/CFT laws, risk indicators, and proper due diligence techniques.
This is your best defense under the “knew or should have known” standard.
2. Policy & Procedure Manuals
Custom-written AML/CFT policy manuals aligned with your company structure and Ministry of Economy requirements.
3. Compliance Officer Support
We can serve as your outsourced Compliance Officer, or provide hands-on support for your in-house MLRO team.
4. goAML Registration & Setup
We handle your goAML and REAR portal setup, ensuring your business is registered, verified, and reporting correctly from day one.
5. AML Gap Analysis & Internal Audit
We identify weaknesses before regulators do – ensuring your firm passes any inspection with confidence.
Why Choose Adilzone?
- UAE-Based Experts: Deep local understanding of DNFBP regulations and FIU processes.
- Certified Specialists: Our consultants are trained in international AML/CFT standards.
- Turnkey Delivery: From policy to portal – we handle it all.
- Zero Disruption: Seamless integration with your existing sales and client onboarding flow.
“The future of UAE real estate belongs to firms built on trust.
Adilzone helps you build that foundation.”
Act Before an Inspection Knocks
Compliance reviews are already underway across the UAE.
Don’t wait for a notice – take control today.
👉 Book your consultation now at Adilzone.com
Let’s secure your firm for 2025 and beyond.
Frequently Asked Questions (FAQ)
Q: What’s the biggest AML risk for real estate agents right now?
A: Cash transactions and incomplete CDD. Any deal involving cash (or its equivalent, including virtual assets) at or above AED 55,000 must be reported — but even below that threshold, unclear source of funds is a red flag.
Q: We’re a small brokerage — do these rules apply to us?
A: Yes. AML/CFT laws apply equally to all real estate DNFBPs. The Ministry of Economy is actively inspecting small and mid-sized firms.
Q: What’s the difference between an STR and a REAR?
A:
- STR (Suspicious Transaction Report): Filed when a suspicious transaction occurs or is attempted.
- REAR (Real Estate Activity Report): Filed for large cash/virtual-asset transactions at or above AED 55,000.
Both are submitted via the goAML portal.
Q: Is checking a passport enough for KYC?
A: No. That’s only identity verification. You must also understand and verify the source of funds, wealth, and ownership structure.
Q: What are common AML “red flags” in real estate?
A:
- Client reluctance to share identity or UBO details.
- Complex corporate structures with no logical reason.
- Third-party payments unrelated to the buyer or seller.
- A sudden buyer name change before contract signing.
- A property purchased without the buyer ever viewing it.
Final Thought
AML compliance is no longer a “back-office” function — it’s a core business strategy.
With Adilzone, you turn compliance from a liability into your strongest competitive advantage.
