AML in UAE Real Estate: What Brokers and Investors Must Understand in 2026

A broker recently closed what seemed like a perfect deal.

A high-value villa was sold, with part of the price paid in cash and part in cryptocurrency. To avoid “scaring off” the client — and the commission — the broker did not verify the Ultimate Beneficial Owner (UBO) and did not submit a report via goAML.

One month later, an inspection arrived from the UAE Ministry of Economy.

The transaction turned out to be part of a money-laundering scheme.

Outcome for the company:

• AED 1.88 million fine
• Revocation of the commercial license

📌 This case is no longer an exception. It reflects how AML enforcement now works in practice in the UAE real estate market.

The “Should Have Known” Principle

Under Federal Decree-Law No. 10 of 2025, the argument “I didn’t know” is no longer a valid defense.

If the circumstances of a transaction were suspicious and a professional party ignored them, liability applies regardless of intent.

In practical terms:

• Ignoring red flags is treated the same as conscious participation
• Lack of documentation or reporting is considered a compliance failure

The AED 55,000 Threshold

For any freehold real estate transaction where payment in cash or virtual assets exceeds AED 55,000, the broker is legally required to submit a REAR report through goAML.

This obligation applies even if:

• The total property price is significantly higher
• Only part of the payment is made in cash or cryptocurrency
• The client insists the source of funds is “clean”

A Common Settlement Trap

From June 2025, new settlement rules apply:

• Foreign sellers must receive sale proceeds only to their own UAE bank account
• Payments to accounts of representatives acting under Power of Attorney (PoA) are no longer permitted

Any deviation from this structure is treated as a compliance breach and may trigger automatic scrutiny.

The Tipping-Off Ban

If a compliance officer files a Suspicious Activity Report (SAR):

• Employees are strictly prohibited from informing the client
• Even indirect hints or warnings are illegal

Violating the tipping-off prohibition is considered a serious federal criminal offence, not an administrative error.

Key AML Risk Metrics in UAE Real Estate

• AED 5,000,000 — maximum administrative fine per violation
• 5 years — mandatory retention period for all transaction documents and correspondence
  (including failed or cancelled deals)
• 24 hours — timeframe to freeze funds if a client matches a sanctions list

Why This Matters in Practice

AML compliance in the UAE is no longer theoretical or selective.

Real estate transactions are now one of the primary enforcement focus areas due to their exposure to cash flows, cross-border structures, and virtual assets.

📌 For brokers, developers, and intermediaries, the real risk is not a single transaction — it is systemic non-compliance.