AML and KYC duties for UAE real estate brokers

The law that applies now

Federal Decree by Law No. 10 of 2025 on anti-money-laundering, combating the financing of terrorism and proliferation financing was issued on 30 September 2025 and, according to the sources, came into force on 14 October 2025. Article 41 repeals Federal Decree-Law No. 20 of 2018, as the official English text and the law firm DLA Piper both report.^[3][4] Its executive regulation, Cabinet Resolution No. 134 of 2025, was published on the Ministry of Economy and Tourism's website on 29 October 2025 and is reported to have come into force on 14 December 2025.^[5]

The 2025 law keeps regulations issued under the 2018 law in effect where they do not conflict, until they are replaced. That is why older Central Bank and Ministry pages, which still cite the 2018 law, remain useful for the design of the regime, although the current texts govern.^[3][4] Commentary on the new package reports three changes: proliferation financing as a standalone offence, tax evasion expressly included among predicate offences, and express coverage of digital systems and virtual assets.^[6]

A practical warning follows from this. Any article that cites Federal Decree-Law No. 20 of 2018 as current describes a repealed statute, and its thresholds and category lists should not be copied across without checking the 2025 texts.

Who is covered

The Central Bank of the UAE's rulebook guidance, in force from 16 June 2021, says real estate agents and brokers qualify as designated non-financial businesses and professions when they conclude operations for customers relating to the purchase and sale of real estate. It says they must then apply the same preventive measures as licensed financial institutions, including risk assessment, customer due diligence and suspicious transaction reporting, and it names the Ministry of Economy as supervisor for the mainland and commercial free zones.^[1]

The current executive regulation carries the designation forward. Cabinet Resolution No. 134 of 2025 lists real estate brokers and agents when concluding transactions or settlements on behalf of their customers on the purchase or sale of real estate.^[5] The trigger is the activity. Whether a firm that only advertises, or only introduces a buyer without concluding a transaction, is covered is a question of fact that the sources reviewed do not resolve.

Commentary reports that developers are folded into the list under the new text.^[6] Other designated categories carried forward conceptually include dealers in precious metals and stones, corporate service providers, auditors and accountants, and lawyers and notaries for specified transactions. Financial free zones such as the DIFC and ADGM run their own equivalent regimes, which this guide does not cover.

What the framework asks of a covered broker

The sources describe the duties in the following terms. They are a summary of commentary and guidance, to be read against the current texts, and not a checklist.

• A risk-based approach and a risk assessment. The Central Bank guidance names risk assessment as one of the preventive measures.^[1]
• Customer due diligence. Identifying the customer and, for a company, the people behind it, is part of the preventive measures. The sources reviewed do not set out the document-by-document content of due diligence for a property transaction.^[1][6]
• A compliance officer. Commentary on the 2025 framework reports that a named compliance officer is required.^[6]
• Registration on goAML. goAML is the platform for suspicious transaction and activity reports. The Ministry's guidance lists real estate brokers and agents as an example of a designated business and warns that failure to register may bring severe penalties, without stating amounts.^[2]
• Suspicious transaction reporting. Commentary reports that reports are required with no minimum value threshold.^[6]
• Record keeping. Commentary reports a five-year retention period.^[6]
• Sanctions screening. The earlier framework required screening customers against the UN and UAE local terrorist and sanctions lists under Cabinet Decision No. 74 of 2020. Whether that decision continues unchanged should be read from the current texts.^[6]

The points reported by commentary, rather than quoted from a text this guide opened, are the compliance officer, the absence of a reporting threshold and the retention period. They should be confirmed in Cabinet Resolution No. 134 of 2025 before an office builds a procedure around them.^[5][6]

What due diligence means in a broker's day

Because the sources do not set the content of due diligence for a property deal, an office has to settle it in a written procedure and check that procedure against the current texts and the Ministry. The questions that procedure needs to answer are practical ones.

• Who is the customer, and have they been identified before a transaction is concluded?
• If the customer is a company, who owns or controls it?
• Who decides whether something looks suspicious, and how does an agent raise a concern without tipping off the customer?
• Who files on goAML, and where is the record kept?

These are prompts for drafting, not statements of what the law requires. The useful discipline is that the procedure exists, that agents have seen it, and that one named person owns it.

Supervision and penalties

Article 17 of the 2025 law is reported to carry the administrative fine range forward unchanged: AED 10,000 to AED 5,000,000 per violation, levied by the sector's supervisory authority, with warnings, suspension, licence revocation and restrictions on directors also available.^[4][6] The criminal fine on a legal person for the laundering offence itself is reported to have risen to a range of AED 5,000,000 to AED 100,000,000 under Article 27.^[4]

The Ministry of Economy and Tourism is named as supervisor for real estate brokers on the mainland and in commercial free zones in the Central Bank guidance.^[1] That guidance pre-dates the 2025 law, and the sources do not include a Ministry circular confirming it under the new text, so the supervisor for a particular licence should be confirmed with the licensing authority.

What Dubai law adds, and what it does not

The Dubai legislation reviewed for this guide imposes no anti-money-laundering or know-your-customer duty on brokers. The only Dubai text on the subject, Law No. 9 of 2019 amending the law that establishes the Economic Security Centre, gives the Centre a function to combat money laundering and the financing of terrorism, which is a government mandate and not a broker duty.^[11] Broker AML duties are federal.

Dubai does set out related duties. The RERA brokerage guide lists ten ethical duties for licensed brokers, among them maintaining privacy and preserving all documents.^[10] For off-plan sales, Executive Council Resolution No. 6 of 2010 provides that a broker engaged by a developer must deposit the sale price into the project escrow account, and may not deposit it into the broker's own account or deduct commission before depositing it.^[12] That rule keeps buyers' money off a brokerage's own books, which is relevant to anyone reading transaction records for unusual activity.

The company behind the broker

A separate federal regime applies to the brokerage as a company. Cabinet Decision No. 58 of 2020, in force from 28 August 2020 and refined by Cabinet Decision No. 109 of 2023, requires mainland and commercial free-zone entities to identify and register their real owners. A beneficial owner is a natural person who ultimately owns or controls 25 per cent or more of the shares or voting rights, directly or indirectly, or who can appoint or remove a majority of the directors; if there is none, a senior managing official is recorded. Entities keep registers, file the data with their registrar and update any change within 15 days.^[7][8]

The penalties reported under Cabinet Decision No. 53 of 2021 escalate from a written warning to AED 50,000 and then AED 100,000 with licence suspension of at least twelve months.^[8] Economic substance reporting, by contrast, is a closed chapter: Cabinet Decision No. 98 of 2024 cancelled notification and reporting for financial years ending after 31 December 2022.^[9]

What the sources leave open

• The exact list of designated businesses and any value thresholds under Cabinet Resolution No. 134 of 2025, which should be re-checked in the text because older guidance mentions thresholds for some categories.
• The detailed content of customer due diligence for a property transaction, including customers who are companies or non-residents.
• Which authority supervises brokers in each licensing jurisdiction beyond the Ministry's role for the mainland and commercial free zones.

The Dubai Land Department and the Ministry are the bodies to ask when a point turns on one of these. A written procedure, one named owner and a dated review of the current texts are the parts of the framework an office can control.

Some CRM products add a restricted queue for anti-money-laundering records. The Works CRM, which The Works Group sells and which is still in build, states on its product page that an agent does not see the AML queue at all, and that only the compliance officer, the owner and the admin do. It is described as a way to keep the records apart, not as a way to meet the law.^[13]

Questions