AML Requirements for Real estate agents and brokers in the UAE
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 the UAE mainland?
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
- Cabinet Resolution No. (134) of 2025, Article 3(2)
- Supervisor
- Ministry of Economy and Tourism
Article 3(2) designates brokers and agents when concluding transactions or settlements on behalf of their customers. The designation attaches to that activity, not to being in the real estate business, so it does not reach a developer selling only its own stock.
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
- Cash at or above AED 55,000 for part or all of the property value, in a single payment or several
- Payment made in a virtual asset for part or all of the property value
- Funds converted from or to a virtual asset for part or all of the property value
MoET Supplemental Guidance for Real Estate Agents and Brokers (March 2026), section 7.1
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
Federal Decree-Law No. (10) of 2025 and Cabinet Resolution No. (134) of 2025, Article 3 governs AML in the UAE mainland. 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.
- Federal Decree-Law No. (10) of 2025 on AML/CFT/CPF, in force 14 October 2025
- Cabinet Resolution No. (134) of 2025, Executive Regulations, in force 14 December 2025 (DNFBPs: Article 3)
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 the UAE mainland, 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.
Other designated businesses in the UAE mainland
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.