AML for Real Estate Brokers in the UAE: REAR Reports, goAML and Virtual Asset Payments (2026)
What UAE real estate brokers and agents must do under the 2025 AML law: when a REAR is due, cash of AED 55,000 or more and virtual asset payments, customer checks, STRs without delay and five-year records.
Short answer: Real estate brokers and agents in the UAE are designated non-financial businesses (DNFBPs) when they conclude purchases or sales of property for their customers. For freehold sales paid with AED 55,000 or more in cash, paid wholly or partly in virtual assets, or funded from virtual assets, they record the parties' identification and the transaction documents and file a Real Estate Activity Report (REAR) on the Financial Intelligence Unit's goAML. Suspicious transactions of any amount go to the FIU immediately and without delay, and records are kept for at least five years.
This guide is for brokerage owners, compliance officers and agents in the UAE. It is a practical guide, not legal advice: check the current texts and guidance from the Ministry of Economy & Tourism.
The rules that apply
Federal Decree by Law No. (10) of 2025, issued on 30 September 2025, is the UAE's anti-money laundering law, and Cabinet Resolution No. (134) of 2025, issued on 29 October 2025, holds its executive regulations. Real estate brokers and agents are DNFBPs "when concluding transactions or settlements on behalf of their customers in relation to the purchase or sale of real estate" (Article 3 of the Resolution). The REAR comes from Ministry of Economy Circular 05/2022, effective 1 July 2022, which stays in force under the 2025 law where it is consistent with it.
When a REAR is due
Circular 05/2022 requires a REAR through goAML for purchases and sales of freehold property, as each emirate's law defines freehold, in three cases:
| Case | What triggers it |
|---|---|
| Cash | A single cash payment, or several, of AED 55,000 or more for all or part of the property value |
| Virtual assets as payment | All or part of the price is paid in virtual assets |
| Funds from virtual assets | The money used for the transaction was converted from a virtual asset |
In each case the broker obtains and records the parties' identification documents (Emirates ID or passport) and the receipts, invoices, contracts and sale and purchase agreement, then submits the REAR.
Because the cash test counts several payments together, deposits, instalments and top-ups on the same property have to be tracked as one transaction. And because the virtual asset tests look at where the money came from, the questions to ask about the source of funds belong in your onboarding, not in a conversation at completion.
Suspicious transactions: any amount, without delay
A REAR is a factual report. A suspicion is reported separately: if you suspect, or have reasonable grounds to suspect, that a transaction or funds are linked to money laundering or terrorist financing, notify the FIU immediately and without delay through its electronic system, whatever the amount and including attempted transactions. The Ministry of Economy & Tourism publishes red-flag indicators and case studies for real estate agents and brokers, and supplemental guidance for the sector, on its AML pages.
Customers, PEPs and sanctions
- Customer due diligence at the start of a business relationship, whenever there is a suspicion, and whenever you doubt identification data you already hold.
- Politically exposed persons: for foreign PEPs, senior-management approval, reasonable measures to establish the source of funds and wealth, and enhanced ongoing monitoring; the same for domestic PEPs where the relationship is high risk.
- Sanctions: targeted financial sanctions instructions from the Executive Office for Control and Non-Proliferation must be implemented forthwith, so buyers, sellers and the people behind corporate buyers are screened before completion.
goAML registration and records
DNFBPs must register on goAML before they can report; the Ministry of Economy & Tourism runs the "Register in goAML" service and warns that failing to register may lead to penalties. Keep records of transactions, customer due diligence, correspondence and reports for at least five years from the end of the transaction or the business relationship (Article 25 of Cabinet Resolution No. 134 of 2025).
A compliance checklist for brokers
- Registered on goAML through the Ministry of Economy & Tourism's service
- Payment method and source of funds captured for every freehold deal
- REAR filed for cash of AED 55,000 or more, single or combined, and for any virtual asset payment or funding
- Identification and transaction documents recorded for each REAR
- Red-flag indicators known to agents, with a fast route to the compliance officer
- STRs filed immediately and without delay, whatever the amount
- PEP and sanctions screening before completion
- Records kept for at least five years
How software helps a brokerage
A brokerage needs a record of each client check, screening against current sanctions lists, a way to spot instalments that together reach AED 55,000 and payments that trace back to virtual assets, and goAML reports the FIU accepts. Creodata's AML compliance software in the UAE covers screening, customer risk rating, case management and reporting, and our goAML reporting software for the UAE generates and validates STR files before submission and can be configured to support REAR reports. For the wider picture, see our UAE goAML reporting guide and our guide for gold and jewellery dealers.
Frequently asked questions
What is a REAR in the UAE?
A Real Estate Activity Report: the goAML report real estate brokers and agents file for freehold purchases and sales paid with AED 55,000 or more in cash, or paid with or funded from virtual assets (Ministry of Economy Circular 05/2022).
Do real estate agents have to report crypto payments?
Yes. A REAR is due when all or part of a freehold purchase is paid in virtual assets, or when the funds used were converted from virtual assets.
Is a REAR the same as a suspicious transaction report?
No. A REAR is due whenever its conditions are met, whether or not anything is suspicious. A suspicious transaction report is filed separately, immediately and without delay, whenever there is a suspicion, whatever the amount.
How long must brokers keep records?
At least five years from the end of the transaction or the business relationship, under Article 25 of Cabinet Resolution No. 134 of 2025.
See how Creodata's AML compliance software in the UAE handles screening and goAML reporting: book a demo.
