12.3 Reporting: goAML, Suspicious Transaction Reports, REAR and Sanctions Screening
Key Takeaways
Suspicious transaction and activity reports have no minimum amount: any reasonable suspicion must be reported to the FIU through goAML.
A REAR is required for a freehold sale or purchase involving cash of AED 55,000 or more in one or several payments, payment in virtual assets, or funds converted from virtual assets.
For a REAR the broker records the parties' identity documents and the receipts, contracts and sale agreement, and files through goAML.
Tipping off a client about a report or investigation is punishable by imprisonment and a fine of at least AED 50,000, or either (Federal Decree-Law No. 10 of 2025).
Clients and beneficial owners must be screened against the UN Consolidated List and the UAE Local Terrorist List, and matched funds frozen without delay.
12.3 Reporting: goAML, Suspicious Transaction Reports, REAR and Sanctions Screening
Due diligence only protects the system if the right reports reach the authorities. A Dubai brokerage files them through goAML, the reporting platform of the UAE Financial Intelligence Unit (FIU).
1. goAML registration
Every brokerage, as a DNFBP, must register on goAML (the organisation and its compliance officer). Without registration it cannot file reports, and failure to register is a programme breach that supervisors penalise. Reports filed in good faith are protected: the reporting entity and its staff are not liable for breach of confidentiality for making them.
2. Suspicion-based reports: STR and SAR
| Report | When | Threshold |
|---|---|---|
| Suspicious Transaction Report (STR) | A transaction or attempted transaction where there are reasonable grounds to suspect the funds are criminal proceeds or linked to terrorism or proliferation financing | No minimum amount |
| Suspicious Activity Report (SAR) | Suspicious behaviour or an approach that does not go ahead as a transaction (for example a buyer who disappears when asked for ID) | No minimum amount |
Reports are filed without delay by the compliance officer after internal escalation. The broker does not need proof of a crime; reasonable suspicion is enough.
Red flags in property deals
- The buyer does not negotiate, or pays well above market; the seller accepts a deep discount for cash.
- Reluctance to provide ID, beneficial-owner details or source of funds; altered documents.
- Payments from unrelated third parties, shell companies or countries with no link to the buyer.
- Rapid resales or off-plan assignments with no commercial reason.
- Payments split into several amounts just below reporting thresholds.
- Pressure to finish unusually fast or to skip normal checks.
3. The Real Estate Activity Report (REAR)
The Ministry of Economy requires real estate brokers and agents, including those in free zones, to submit a REAR through goAML for freehold sale and purchase transactions in three cases:
- Cash: a single cash payment, or several, amounting to AED 55,000 or more for all or part of the property's value.
- Virtual assets: payment of all or part of the value in virtual assets.
- Converted funds: funds used for the transaction that were converted from virtual assets.
For each REAR the broker records the parties' identification documents (Emirates ID or passport) and the receipts, invoices, contracts and sale agreement, and keeps them for at least five years.
| STR / SAR | REAR | |
|---|---|---|
| Trigger | Suspicion | Objective payment facts |
| Threshold | None | AED 55,000 cash; any virtual assets |
| Implies wrongdoing? | Indicates suspicion | No; it is a threshold report |
| Can be filed together? | Yes, if a REAR deal is also suspicious, both are filed |
4. Tipping off
Article 24 of Federal Decree-Law No. 10 of 2025 prohibits notifying or warning anyone, or disclosing information, about transactions under review as suspicious, or revealing that the authorities are conducting inquiries or investigations. Article 29 punishes breaches with imprisonment and a fine of not less than AED 50,000, or either penalty. In practice:
- Do not tell the client that a report is being or has been filed.
- Continue to ask for normal documents politely; escalate internally to the compliance officer.
- Do not confront the client with your suspicion.
5. Targeted financial sanctions
Brokerages must screen buyers, sellers, signatories and beneficial owners against the UN Consolidated List and the UAE Local Terrorist List (subscribing to the Executive Office for Control and Non-Proliferation's notifications).
- Confirmed match: freeze the funds or assets without delay and without prior notice to the customer, do not proceed with the transaction, and report through goAML (a funds freeze report) as the EOCN and FIU guidance requires.
- Partial match: if a name match cannot be ruled out, suspend the transaction and file a partial name match report while it is resolved.
- No tipping off: the customer must not be told.
Breaching targeted financial sanctions instructions is a separate offence under the 2025 law.
6. Worked scenarios
| Scenario | Correct action |
|---|---|
| Buyer pays AED 30,000 in cash and the rest by bank transfer; nothing suspicious | No REAR (cash below AED 55,000); normal CDD and records |
| Buyer pays AED 20,000 in cash on three separate days for one freehold unit | REAR: several cash payments totalling AED 60,000 meet the AED 55,000 threshold |
| Buyer settles 10% of the price in a stablecoin through a licensed virtual asset provider | REAR for virtual-asset payment, plus enhanced checks on the source of the assets |
| Seller asks for the price to be paid to an unrelated offshore company and refuses to explain | Escalate to the compliance officer; consider an STR; do not tip off |
| A screening tool shows the buyer's name matches a person on the UAE Local Terrorist List, with the same date of birth and passport number | Confirmed match: freeze without delay, stop the transaction, report through goAML, do not tell the buyer |
7. What the compliance file should show
For every report the file should show who raised the concern and when, what the compliance officer reviewed, the decision and its reasons, the goAML reference, and copies of the documents relied on, all kept for at least five years. Supervisors test not only whether reports were filed but whether decisions not to report were reasoned and recorded.
A buyer pays a AED 60,000 cash booking deposit on a AED 950,000 freehold apartment and settles the AED 890,000 balance by manager's cheque. Identification is complete and nothing is suspicious. What must the broker file?
A suspicious transaction report, because any cash over AED 10,000 is presumed laundering
Nothing, because most of the price was paid by cheque
A Real Estate Activity Report, because AED 55,000 or more was paid in cash in a freehold sale
A funds freeze report, because cash over AED 50,000 must be frozen
A sales agent, worried about the client, phones an investor to say: "Our compliance team is filing a suspicious transaction report on your funds, so you should cancel." What is the legal consequence under Federal Decree-Law No. 10 of 2025?
None, because the agent was protecting the client
An internal reprimand only, if the sale is cancelled
A AED 10,000 municipal fine payable at licence renewal
The agent has committed tipping off, punishable by imprisonment and a fine of at least AED 50,000, or either, besides disciplinary consequences
A broker becomes suspicious that funds for a AED 40,000 annual lease deposit come from fraud. The amount is small. Must a report still be considered?
No, suspicious reports apply only above AED 55,000
Yes: suspicious transaction and activity reports have no minimum amount, so reasonable suspicion must be escalated and reported through goAML
No, leases are outside AML rules
Only if the landlord agrees
Sections you finish are checked off in the contents.