Why property attracts laundering
- High values in one transaction, so a single deal can move a large sum.
- Buyers who never live in the property, and often never appear in person.
- Off-plan purchases and resale before completion, which can transfer an interest without money visibly changing hands.
- Corporate and offshore buyers standing between the funds and a person.
- Third-party payments, where the payer is not the buyer.
- Undervaluation or overvaluation used to justify a movement of funds.
Real estate professionals are DNFBPs
Real estate brokers and agents are designated non-financial businesses and professions under UAE AML legislation, supervised at state level and in commercial free zones by the Ministry of Economy and Tourism. That brings registration on the goAML portal, and a set of controls you should be able to show.
If you also hold or manage rental funds, or act for both sides of a transaction, your risk profile — and your controls — need to reflect that.
Controls that fit a property business
- Identify and verify buyer and seller, and for a corporate buyer, its ultimate beneficial owners.
- Screen every party at the point of instruction, and again before completion — status can change while a deal is in progress.
- Ask where the funds come from for larger or unusual purchases, and keep the answer on file.
- Refuse or escalate third-party payments where the payer cannot be identified and explained.
- Record who you verified, when, against which list, and what you concluded.
- Train agents on what to look for and how to escalate, and record the training.
- Appoint a compliance officer who can actually stop a deal.
Red flags worth writing down
- A buyer who wants to complete quickly and shows no interest in price or condition.
- Payment from an account in a different name, or from several accounts.
- Cash or near-cash instruments in amounts unusually close to a threshold.
- A newly formed company with no trading history buying residential property.
- A purchase priced well away from market value.
- A buyer who asks who else has seen the file, or who will not provide ownership information.
Reporting
Where you suspect proceeds of crime, the route is a suspicious transaction or activity report to the UAE Financial Intelligence Unit through goAML. Do not tell the customer. Where you are unsure, escalate internally and document the decision — a well-recorded decision not to report is defensible, an undocumented one is not.
Frequently asked questions
Do agents have to register on goAML?
Real estate brokers and agents are DNFBPs, and DNFBPs are required to register on the goAML portal so they can file suspicious transaction and activity reports. Registration runs through the business's supervisory body.
Do we screen the buyer or the property?
The parties, not the property. Screen buyer, seller, and any beneficial owner or authorised signer, plus anyone paying on a buyer's behalf.
Can we accept a deposit in cash?
Cash is not prohibited, but it raises the standard of what you must document — source of funds, identity of the payer, and the reason for the method. Set an internal limit and a documented escalation route above it.
At what point should screening happen?
At instruction, before you act on the deal, and again before completion. A list can change while a transaction is in progress.
This guide is general information about compliance expectations in the UAE, written by our team. It is not legal advice and does not replace the guidance of your supervisory body. Where an obligation depends on your licence, activity or free zone, confirm it with your supervisor or a qualified adviser.