Anti money laundering duties for agents

Who does anti money laundering law apply to in a brokerage?

Real estate brokers and agents are designated non-financial businesses and professions under UAE anti money laundering law. Cabinet Resolution No. 134 of 2025 defines the category to include "real estate brokers and agents, when concluding transactions or settlements on behalf of their customers in relation to the purchase or sale of real estate."

The supervisor is the Ministry of Economy and Tourism. Its Supplemental Guidance for Real Estate Agents and Brokers, published in March 2026, says brokerages are required to run a risk-based anti money laundering framework under its supervision, and that the guidance applies to the members of a firm's board, its management and its employees.

The law itself changed recently. Federal Decree by Law No. 10 of 2025 came into force on 14 October 2025 and repealed the 2018 decree-law, which much older material on this subject still cites. Its executive regulations, Cabinet Resolution No. 134 of 2025, have applied since 14 December 2025. The new law keeps circulars issued under the old one in effect where they do not conflict with it, until they are replaced, and the Ministry's March 2026 guidance restates the report its 2022 circular set, described below.

So the duties are written for the business, and an agent works inside them. The firm registers, reports and keeps the records. An agent is usually the first person to see a passport, hear how a buyer means to pay, or notice that a story does not add up.

When does a sale have to be reported?

The Ministry of Economy's Circular 05/2022, in effect since 1 July 2022, requires a Real Estate Activity Report, known as a REAR, on three kinds of freehold sale or purchase. Each one is submitted to the Financial Intelligence Unit through its goAML platform, and each needs identification and the transaction documents collected and recorded first.

The trigger is how the purchase is paid for, not whether anything looks wrong. The Ministry's 2026 guidance puts it plainly: "The obligation to submit REARs is not risk-dependent and must be fulfilled even when Customer Due Diligence measures have been satisfactorily completed and no red flags have been identified." A clean, well documented cash buyer is still a report.

Two details are worth knowing. The cash case is physical cash, in the circular's own words, and the FIU, asked whether international bank transfers from individual clients above AED 55,000 need a REAR, answers no. And the third case is worded differently in two places: the circular says funds "converted from" a virtual asset, while the 2026 guidance says "converted from or to". Your compliance officer decides how the firm reads it.

Neither the circular nor the 2026 guidance states a deadline for submitting a REAR; the guidance refers to "predefined parameters and timelines" without setting them out. Ask your compliance officer what the firm's timeline is, and tell them as soon as a trigger appears rather than at transfer.

The virtual asset cases, and the conversation with a client who wants to pay in crypto, have their own piece in this guide.

What do you collect from a client, and how long is it kept?

Identification comes first, and earlier than many agents expect. Article 6 of Cabinet Resolution No. 134 of 2025 requires, as the general rule, the customer's identity to be verified before or during the establishment of a business relationship. The Ministry's 2026 guidance says that, in real estate, a relationship is established when, among other things, a listing agreement or similar document is signed, instructions are received to act for a client, or a fee is received. That is the start of the work, not the transfer.

What is collected is set out in the regulations and in the circular. For a company, the circular adds its trade licence, articles of association and register of beneficial owners, and identification for every beneficial owner and shareholder or partner. The regulations treat anyone who ultimately owns 25% or more of a company as a beneficial owner to be identified.

Records are kept for not less than five years. Article 25 of the regulations counts that from the completion of the transaction or the end of the business relationship, and for due diligence records from the latest of several events, including the end of an inspection or investigation. Records must be organised well enough to reconstruct a transaction and must be produced to the authorities promptly on request, which is why a copy of a passport belongs in the firm's system rather than in a chat thread on your phone.

1. 01

   For an individual

   Name as it appears on the identity document, nationality, address, date and place of birth, the employer's name and address where applicable, and a true copy of a valid identity card or travel document. Article 9 of the regulations.

2. 02

   For someone acting for the client

   Proof that they are authorised, such as a power of attorney, and their own identification to the same standard. Article 9(2).

3. 03

   For a company

   Name, legal form, constitutional documents and registered address, the names of its senior managers, and the natural persons behind it. The circular adds the register of beneficial owners and identification for every shareholder or partner.

4. 04

   Purpose, and the money

   The regulations require an understanding of the purpose of the relationship. The Ministry's guidance adds sanctions screening of customers and beneficial owners, and a source of funds check on every transaction, in more depth where the risk is higher.

What is goAML, and do you register on it yourself?

goAML is the Financial Intelligence Unit's reporting platform. The FIU states that all reports must be submitted through it, a REAR and a suspicious transaction report alike, and that a reporting entity has to be connected to it to submit one.

Registration is the firm's, not the individual agent's. The FIU's published answers describe an organisation registering first, with its supervisory body approving the registration, and the compliance officer as the registering person. Other staff can then be added as users under the firm's organisation number. Asked directly whether individual brokers need their own FIU account for REAR, the FIU answers that it is ideally the compliance officer's responsibility, and that firms with a high volume of transactions may add users.

The Ministry treats registration as a hard requirement. In August 2023 it announced that it had suspended the operations of 50 businesses across the designated non-financial sector for three months in that quarter for failing to register on goAML, naming real estate agents among the businesses it supervises.

For an agent, the practical point is simpler. Unless your firm adds you as a goAML user, you will not need a login to meet your part of this. You need to know who your firm's compliance officer is, and how they want a trigger or a concern raised.

What does the compliance officer do, and what if something looks wrong?

Every brokerage has to appoint a compliance officer at management level, with independence in decision making and the competence and experience for the job. Article 22 of the regulations lists the duties: monitoring transactions, receiving and assessing suspicious transaction information and deciding in full confidentiality whether to notify the FIU, reviewing the firm's procedures, training staff, and cooperating with the Ministry and the FIU.

A suspicious transaction report is a different thing from a REAR. A REAR follows from the payment method and the threshold. A suspicious transaction report follows from suspicion, or reasonable grounds for it, and Article 18 of the regulations applies it "regardless of their value". The Ministry's guidance is clear that both can apply to the same sale, and the circular says a REAR does not replace the firm's other reports.

There is also a separate duty attached to suspicious transaction reports. If a transaction looks wrong to you, speak to your compliance officer.