AML Requirements for Real estate agents and brokers in ADGM
Firms concluding purchase or sale transactions for customers, including brokerages, developers with an in-house sales arm, property managers and leasing agents.
Are real estate agents and brokers designated in ADGM?
It depends on what the firm does for its customers. The designation attaches to particular activities rather than to holding a licence, so two firms with the same licence can sit on opposite sides of the perimeter.
- Designating provision
- ADGM AML Rulebook, DNFBP definition (a)
- Supervisor
- ADGM Registration Authority
An agency "which carries out transactions for or on behalf of a customer involving the buying or selling of real property". The same activity test as the federal provision, in almost the same words.
Because the test turns on the firm's own activity, the free scope check puts the question that decides it and states the answer with the provision behind it.
Reports filed with no suspicion required
- A total cash payment of USD 15,000 or more for the sale or purchase, in a single payment or several
- Payment for part or all of the amount made using virtual assets
- Payment for part or all of the amount including funds converted from or to a virtual asset
ADGM AML Rulebook, rule 8.1.1(7)(b)
These are not risk-based. They are due whenever the trigger is met, even where due diligence is complete and nothing looks wrong, which is why an unfiled one is a strict-liability gap rather than a judgement call.
What the regime requires here
ADGM Anti-Money Laundering and Sanctions Rules and Guidance (AML), made by the FSRA under the Financial Services and Markets Regulations 2015 governs AML in ADGM. Every designated firm owes the same spine of obligations: a documented risk assessment covering money laundering, terrorist financing and proliferation financing; customer due diligence with enhanced measures for higher risk and for high-risk countries; policies approved by senior management; a compliance officer at management level; an independent audit of the controls; immediate implementation of targeted financial sanctions; staff training; and records available to the authorities on request.
- ADGM Anti-Money Laundering and Sanctions Rules and Guidance (AML)
- ADGM Financial Services and Markets Regulations 2015
What Federal Decree-Law No. 10 of 2025 changed sets out the obligations and the penalties in full, with each article cited.
See where this firm actually stands
AML Compass assesses a real estate agents and broker against the duties that apply in ADGM, scores its risk and inspection readiness, and produces a report of the gaps citing the provision behind each one.
The same sector elsewhere in the UAE
The designation, the threshold and the supervisor are not the same across jurisdictions, so a firm operating in more than one needs both answers.
This page summarises published legislation and rulebooks for general information. It is not legal advice, and it does not replace the texts themselves or guidance from your supervisor.