12.1 The UAE AML/CFT Framework for Real Estate Brokers (2025 Law)
Key Takeaways
Federal Decree-Law No. 10 of 2025 came into force on 14 October 2025 and repealed Federal Decree-Law No. 20 of 2018.
Cabinet Resolution No. 134 of 2025, effective 14 December 2025, replaced Cabinet Decision No. 10 of 2019 as the implementing regulation.
Real estate brokers and agents are DNFBPs; for brokers licensed on the mainland and in non-financial free zones the AML supervisor is the Ministry of Economy.
Under the 2025 law, supervisors may impose administrative fines from AED 10,000 to AED 5,000,000 per violation, plus suspension or licence revocation.
A person who commits money laundering faces 1 to 10 years' imprisonment and a fine of AED 100,000 to AED 5,000,000 or the value of the property, whichever is greater.
12.1 The UAE AML/CFT Framework for Real Estate Brokers (2025 Law)
Property is attractive to criminals because large sums can be moved in one transaction and later sold or rented as "clean" assets. The UAE therefore treats real estate brokers as gatekeepers. The legal framework changed in 2025, so make sure your notes use the current law numbers.
1. The current legal framework
| Instrument | Status | What it does |
|---|---|---|
| Federal Decree-Law No. 10 of 2025 on anti-money laundering, combating the financing of terrorism and the financing of proliferation | Published 30 September 2025; in force 14 October 2025; repealed Federal Decree-Law No. 20 of 2018 (and its 2021 amendments) | Defines the offences, the duties of financial institutions, DNFBPs and virtual asset service providers, supervisory powers and penalties |
| Cabinet Resolution No. 134 of 2025 (implementing regulation) | In force 14 December 2025; replaced Cabinet Decision No. 10 of 2019 | Detailed rules on risk assessment, customer due diligence, beneficial owners, politically exposed persons, internal controls and record-keeping |
| Cabinet Decision No. 109 of 2023 on beneficial owner procedures | In force; replaced Cabinet Decision No. 58 of 2020 | Defines beneficial owners (25% ownership or control) and the registers companies must keep |
| Ministry of Economy circulars for real estate brokers | In force | Five-year record-keeping and the Real Estate Activity Report (REAR) for cash and virtual-asset deals |
| Targeted financial sanctions rules | Administered with the Executive Office for Control and Non-Proliferation (EOCN) | Screening against the UN Consolidated List and the UAE Local Terrorist List; freezing without delay |
The 2025 law also added proliferation financing as an offence, brought virtual assets expressly into scope and lowered the knowledge threshold for money laundering: liability can arise where there are sufficient indications that funds are criminal proceeds.
2. Brokers as DNFBPs and who supervises them
Designated non-financial businesses and professions (DNFBPs) include real estate brokers and agents when they act in transactions for the purchase or sale of real estate, as well as dealers in precious metals and stones, lawyers and notaries, accountants, corporate service providers and (since 2025) commercial gaming operators.
- Supervisor: the Ministry of Economy supervises real estate brokers and agents licensed in the UAE mainland and in non-financial free zones; firms in the DIFC and ADGM fall under those financial centres' regulators.
- DLD's role: DLD licenses brokers and offices, controls Trakheesi and runs the registers; it does not replace the Ministry as AML supervisor, but AML failures also affect a broker's standing with DLD.
- FIU: suspicious transaction reports and REARs go to the UAE Financial Intelligence Unit through the goAML platform.
3. The compliance programme a brokerage must run
- Register on goAML (the organisation and its compliance officer) so the firm can file reports.
- Enterprise-wide risk assessment covering customers, countries, products and payment methods (for example cash, virtual assets, off-plan flipping) and delivery channels (remote or face-to-face), documented and kept up to date.
- Policies, controls and procedures for customer due diligence, enhanced due diligence, beneficial owners, sanctions screening, internal reporting and record-keeping.
- Compliance officer with the competence, seniority, independence and access to records needed to review suspicions and file reports.
- Training for brokers and staff, and screening of employees.
- Independent audit of the programme, proportionate to the firm's size.
- Record-keeping of customer, transaction and report records for at least five years.
4. Money laundering in real estate: the three stages
| Stage | Real estate example |
|---|---|
| Placement | Paying a booking deposit in cash, or with virtual assets, to get illicit money into the system |
| Layering | Rapid resales or assignments of off-plan units, use of shell companies, nominees or third-party payers to hide the source |
| Integration | Renting out or selling the property so the proceeds look like normal investment income |
5. Penalties under the 2025 law
| Breach | Penalty (Federal Decree-Law No. 10 of 2025) |
|---|---|
| Regulatory breaches by a supervised entity | Administrative fines from AED 10,000 to AED 5,000,000 per violation, plus warnings, bans, suspension of managers or activity, or licence revocation |
| Money laundering by an individual | 1 to 10 years' imprisonment and a fine of AED 100,000 to AED 5,000,000 or the value of the criminal property, whichever is greater (Article 26) |
| Money laundering by a legal person | Fine of AED 5,000,000 to AED 100,000,000 or the value of the property, whichever is greater |
| Tipping off | Imprisonment and a fine of at least AED 50,000, or either (Article 29) |
| False or misleading beneficial-owner information | Imprisonment and a fine of at least AED 20,000, or either (Article 35) |
A brokerage's AML manual, last updated in 2024, cites Federal Decree-Law No. 20 of 2018 and Cabinet Decision No. 10 of 2019 as the governing rules. What should the compliance officer update?
Nothing: those instruments remain in force
Only the training log
The citations: Federal Decree-Law No. 10 of 2025 (in force 14 October 2025) repealed the 2018 law, and Cabinet Resolution No. 134 of 2025 (from 14 December 2025) replaced Cabinet Decision No. 10 of 2019
Only the beneficial ownership rules, which moved to the Civil Transactions Law
Which authority supervises AML/CFT compliance for a real estate brokerage licensed on the Dubai mainland?
The Ministry of Economy, as supervisor of real estate brokers and agents licensed on the mainland and in non-financial free zones
The Dubai Financial Services Authority
The Rent Disputes Settlement Centre
Dubai Municipality
A brokerage ignores repeated supervisory instructions to register on goAML and to complete its enterprise-wide risk assessment. Under Federal Decree-Law No. 10 of 2025, what range of administrative fine can the supervisor impose per violation?
A flat AED 5,000 at licence renewal
No fine for a first breach
AED 10,000 to AED 5,000,000 per violation, alongside other measures such as suspension or licence revocation
Only criminal penalties, with no administrative fines
Sections you finish are checked off in the contents.