What to do when a client says they want to pay in crypto
The short answer
Tell the client in one sentence: a UAE seller cannot take crypto, so a licensed provider converts it to dirhams first. Then ask what they hold, whether they can evidence how they got it, and whether they have converted. Never quote a rate or take crypto yourself, and tell your compliance officer, because the sale is reportable.
Most agents handle this one of two ways. They say yes, because the client is keen and a developer's brochure says crypto accepted, and promise something the law does not allow. Or they say it is complicated and watch the lead go to someone who said yes. There is a third answer. It takes two minutes, it is true, and it is the one that keeps the client.
By House Of Orange editorial. A licensed Dubai real estate brokerage, ORN 49865, at The Opal Tower, Business Bay. About the firm
Key points
- The rule
- Article 2(7) of the Central Bank's Payment Token Services Regulation, in force since 31 August 2024
- It covers services too
- So it covers your brokerage. Commission cannot be taken in crypto any more than a price can
- The report
- Every freehold sale paid in, or converted from, a virtual asset is reportable by the broker. No minimum amount, since 1 July 2022
- Records
- Identification and contracts, kept for not less than five years
- What never changes
- The fees, and the time registration takes. Crypto speeds up nothing
What can you truthfully say in the first minute?
The client has usually read that Dubai property can be bought with Bitcoin, and much of what they read predates the rule or ignores it. You do not need to give a lecture. You need four sentences that are true, in an order that keeps them in the room.
The seller is paid in dirhams
Since 31 August 2024 a Central Bank regulation has barred a business in the UAE from accepting a virtual asset as payment unless it is a licensed dirham payment token. A developer is a business. Bitcoin, Ether and USDT are not licensed dirham tokens.
So the crypto is sold first, by a licensed firm
The client sells the asset for dirhams through a licensed provider and buys with the dirhams. That is lawful, it is ordinary, and it is what every serious buyer in their position does.
It costs what any purchase costs, plus the conversion
The 4% registration fee, the trustee fee and the commission are the same as for any buyer. The conversion is an extra cost, paid to the provider through its fee and its rate. It is never free.
It is not faster
Registration takes the same time however the dirhams were raised. If anything it needs more lead time, because the provider's checks come first.
Which three questions qualify the lead?
Interest is not the question. Whether this person can arrive at a trustee office with cleared dirhams on a fixed date is. Three questions tell you, and none of them is rude if you explain why you are asking.
What do you hold?
A volatile coin, a dollar stablecoin, or dirhams already. The first is a price risk between offer and conversion. The second is mostly a paperwork question. The third is a cash buyer, and should be treated as one from that moment.
Can you show how you came to hold it?
A licensed provider has to verify its client, and for a higher risk client it must identify and verify the source of funds and of wealth. A buyer who cannot evidence the history will not get through onboarding, whatever the balance says. Better to find that out before the viewing than after the offer.
Have you got a provider, and have you converted?
If yes, ask which firm and check it on the Virtual Assets Regulatory Authority's public register, which lists approvals in principle beside full licences. If no, the honest advice is to open that relationship before making an offer, because nobody publishes how long onboarding takes.
What must you never do?
Each of these is usually done to be helpful. Each is a way to lose a client, a commission, or worse.
Never take any of it in crypto yourself
Article 2(7) is written about a person selling goods or services in the course of business. Brokerage is a service. A deposit, a commission or a holding fee paid to you or your firm in a virtual asset is the thing the rule prohibits.
Never say a seller or developer accepts crypto without asking how
If a developer advertises it, ask who converts the asset, under which licence, and what dirham amount is credited to the unit. Then tell the client that is what is happening. Repeating the brochure makes the promise yours.
Never quote a rate, or say there are no fees
You are not the provider and you do not know its spread. Say the conversion has a cost, that it is paid through a fee and a rate, and that the client should ask for the dirhams delivered for a stated amount of the asset.
Never introduce a desk you have not checked
An introduction is a recommendation. If the firm is not on a regulator's register, licensed for an activity that covers conversion, do not make it.
Never advertise a listing as crypto accepted on your own initiative
The same article restricts promotion of services relating to a means of payment, to those relating solely to licensed dirham tokens or to registered foreign tokens used to buy virtual assets. How that applies to a listing is a question for your compliance officer, before the advert and not after.
What does your brokerage have to report?
Real estate brokers and agents are designated non-financial businesses under the UAE's anti money laundering framework, supervised by the Ministry of Economy and Tourism. Cabinet Resolution No. 134 of 2025 names them when they conclude transactions on behalf of customers in relation to the purchase or sale of real estate.
A Ministry circular applying from the beginning of July 2022 obliges brokers and agents to report three kinds of freehold sale. One is physical cash of AED 55,000 or more. The other two are any sale where the method of payment is a virtual asset, and any sale where the funds used were transferred from a virtual asset into cash, for the whole of the value or part of it. Neither has a minimum amount.
Read the last one again. A client who does everything properly, converts through a licensed provider and pays in dirhams, is still a reportable sale. The trigger is how the purchase was funded, not whether anything looks wrong.
What that means you collect
For an individual, a copy of a valid Emirates ID or passport. For a company, its commercial licence, its statutes, its register of beneficial owners, and identification for the people behind it. Plus the contracts. The Ministry's announcement lists them.
How long it is kept
Not less than five years. That is in the Ministry's circular and in the executive regulations.
Who you tell, and when
Your firm's compliance officer, as soon as the client says the word crypto, not when the offer is accepted. The report is the firm's to make. Knowing it is coming is yours.
How do you write it into the deal?
The memorandum of understanding states a dirham price and a transfer date. If the buyer's money is still in crypto on the day it is signed, the contract is fixed and their funds are not, and the seller is the one who does not know it.
So agree in writing the date by which the buyer will show cleared dirhams in an account in their own name, and what happens if that date passes. It protects the seller, it protects your transfer date, and a buyer who has already converted will sign it without a second thought. One who hesitates has told you something.
Put it inside the contract, not beside it. The Land Department's Contract F, which the market calls Form F, has a place for additional conditions, and the Department's walkthrough for brokers shows a step for additional terms when the contract is created. Its published template says conditions in any other document that conflict with the contract are not valid against the parties. A clause agreed over WhatsApp is the one nobody can rely on.
What this page relies on
Government bodies and regulators only. Each link carries the date we last read it against the text above.
- Executive Council Resolution No. (30) of 2013 Approving the Fees of the Land Department (the 4% registration fee)
- Central Bank of the UAE, Payment Token Services Regulation, Article 2: prohibitions on activities and promotions
- Ministry of Economy and Tourism, announcement of the circular obliging brokers and agents to report and keep records, 7 July 2022
- Cabinet Resolution No. (134) of 2025, executive regulations of the anti money laundering law, on the Central Bank rulebook
- Virtual Assets Regulatory Authority, Compliance and Risk Management Rulebook, client due diligence
- Dubai Land Department, Property Sales Contract between Seller and Buyer (Contract F), published template
- Virtual Assets Regulatory Authority, public register
Questions about this
The ones that come up most often, answered without a pitch.
No. Article 2(7) of the Central Bank's Payment Token Services Regulation, in force since 31 August 2024, bars a person selling goods or services in the course of business from accepting a virtual asset as payment unless it is a licensed dirham payment token. Brokerage is a service, so the rule covers commission and deposits as it covers a price.
Your brokerage does. Since the beginning of July 2022 a Ministry of Economy circular has required brokers and agents to report any freehold sale paid in a virtual asset, or funded by converting one, for all or part of the value, with no minimum amount. Physical cash is reportable from AED 55,000. Tell your compliance officer early.
That the seller is paid in dirhams, so the Bitcoin is sold through a licensed provider first and the property is bought with the proceeds. That the 4% fee and the other costs are the same as for any buyer, plus the conversion. And that they should open the relationship with a provider before they make an offer.
Not on your own initiative. Article 2(10) of the same regulation restricts promotion of services relating to a means of payment, and Article 2(7) restricts what the seller may accept in the first place. Take the wording to your compliance officer before it goes on a portal, where it sits under your name and your permit number.
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Written by House Of Orange, a licensed Dubai brokerage that also recruits agents
House Of Orange Real Estate is a licensed Dubai brokerage, ORN 49865. We publish this because we recruit, and we would rather you put the questions on these pages to us than take our word for anything. If a firm cannot answer them, that is the answer.