Is Your AML Policy Still Fit for a Real Estate Brokerage in the UAE?

If your AML policy for your real estate brokerage in the UAE hasn't been touched since before October 2025, there's a good chance it's citing a law that no longer exists.

For years, almost every AML policy template handed to UAE real estate brokerages pointed to the same two references: Federal Decree-Law No. 20 of 2018 and Cabinet Decision No. 10 of 2019. Both were repealed in late 2025. The law that replaced them — Federal Decree-Law No. 10 of 2025, in force since 14 October 2025, backed by Cabinet Resolution No. 134 of 2025 from December 2025 — didn't just update a few clauses. It rewrote the risk entirely, and with it, what a compliant AML policy for a real estate brokerage actually needs to contain.

What Actually Changed

A few changes matter more than the rest, especially if you run or manage a brokerage:

• The penalty ceiling for legal persons jumped to AED 100 million. That's not a typo, and it's not limited to banks — real estate brokerages, as Designated Non-Financial Businesses and Professions (DNFBPs), fall squarely within scope.
• The evidentiary threshold for money laundering was lowered, meaning prosecutors and regulators now need less to build a case than they did under the old law.
• False UBO (Ultimate Beneficial Owner) reporting is now a criminal offence, not just an administrative breach. If a buyer's declared ownership structure turns out to be inaccurate and your brokerage didn't catch it, that's no longer a paperwork problem.
• The tipping-off offence was expanded, tightening what your staff can and can't say to a client once a suspicious transaction report has been filed.

If your policy documents, training materials, or CDD checklists still reference the 2018/2019 framework, they're not just outdated — they're actively misleading anyone relying on them.

The Rule Most Brokerages Don't Realise Applies to Them

Since 1 July 2022, real estate brokers have been required to file a Real Estate Activity Report (REAR) — a separate, additional obligation that sits on top of standard Suspicious Transaction Reports and CDD requirements — whenever a freehold sale or purchase involves:

• A single or linked cash payment of AED 55,000 or more, or
• Any portion of the property value paid in virtual assets, or
• Funds converted from a virtual asset into cash for any part of the transaction

This isn't an edge case. Cash-heavy transactions and crypto-funded purchases are common enough in Dubai's freehold market that many brokerages are likely filing REARs inconsistently — or not at all — without realising the gap exists. A REAR does not replace your other reporting duties. It's additional, and missing it is treated as its own violation.

Why the Timing Makes This Urgent

Two things are converging right now that make this more than a routine compliance update:

First, enforcement has already accelerated. The Ministry of Economy has imposed more than AED 130 million in administrative fines on DNFBPs since late 2022, with AED 42 million of that in just the first half of 2025 — before the new law even took effect. Real estate brokers are consistently named among the most frequently inspected DNFBP categories.

Second, the UAE is preparing for its next FATF mutual evaluation in 2026. Ahead of major FATF reviews, regulators in every jurisdiction tend to inspect harder, fine faster, and make examples of sectors seen as historically weak links — and real estate has been flagged as exactly that kind of sector globally, not just in the UAE.

Put those together, and a brokerage running on a pre-2025 policy isn't just slightly behind. It's walking into an inspection window with the wrong playbook.

What to Check in Your AML Policy Before an Inspector Does

A quick internal review of your real estate brokerage's AML policy should cover:

1. Does your written AML/CFT policy reference Federal Decree-Law No. 10 of 2025 and Cabinet Resolution No. 134 of 2025 — or does it still cite the repealed 2018/2019 framework?
2. Is your team actually filing REARs for qualifying cash and virtual-asset transactions, or has this obligation been overlooked?
3. Has your UBO verification process been tightened to reflect the new criminal liability for false reporting?
4. Is your goAML registration current, and is your designated compliance officer actually resourced to do the job?
5. When was your CDD and sanctions screening process last independently reviewed — not just signed off internally?

If you can't answer all five confidently, that's the gap an inspector will find first.

Where to Go From Here

Updating an AML policy for a real estate brokerage in the UAE sounds simple until you're the one doing it — mapping every clause to the new legal references, rebuilding CDD workflows around a lower evidentiary threshold, and making sure REAR filing is actually happening on the ground, not just written into a policy no one follows.

This is exactly where an experienced AML Consultant UAE earns its fee — not by handing you a template, but by reviewing your actual transaction files, testing whether your REAR filings hold up, and rebuilding what's genuinely outdated before a regulator flags it for you.

ASC Global UAE offers a focused AML Audit Service UAE brokerages can use to benchmark their current policy against Federal Decree-Law No. 10 of 2025 in a matter of days, not months. If you manage or advise a real estate brokerage and haven't reviewed your AML framework since the law changed, that review is worth doing now — not after an inspection notice arrives.