Real estate developers are DNFBPs (designated non-financial businesses and professions) under UAE AML law, and since 14 October 2025 the rules they follow are set by Federal Decree-Law No. 10 of 2025 — a stricter framework than the 2018 law most developers built their compliance on.
TL;DR
- Federal Decree-Law No. 10 of 2025, effective 14 October 2025, replaced Federal Decree-Law No. 20 of 2018 as the core AML law.
- Its Executive Regulations, Cabinet Resolution No. 134 of 2025, came into force on 14 December 2025.
- Developers selling off-plan or completed units are supervised for AML by the Ministry of Economy (MoET) on the mainland, and by the relevant free zone or financial-free-zone authority where applicable.
- Large-cash and virtual-asset property transactions trigger reporting obligations through goAML; the AED 55,000 cash threshold used across real estate reporting applies to reportable transactions.
- Customer due diligence records, beneficial ownership data and transaction files must be retained for at least five years.
Why the 2025 framework changes developer compliance
The 2018 law and its 2019 Executive Regulations were the basis of most developer AML programmes. Both have been replaced. Federal Decree-Law No. 10 of 2025 (issued 30 September 2025, in force 14 October 2025) broadened the preventive-measures regime and raised the stakes for legal persons; Cabinet Resolution No. 134 of 2025 (in force 14 December 2025) rewrote the operating rules. Programmes built on the old texts need a gap review — particularly on customer risk assessment, beneficial ownership verification and record-keeping scope, which the 2025 regulations define more expansively (screening logs, internal analyses and monitoring outputs are now expressly covered).
What the law requires of a developer
| Obligation | What it means in practice | Reference |
|---|---|---|
| AML/CFT compliance programme | Written policies, an appointed compliance officer, risk-based controls | Federal Decree-Law No. 10 of 2025 |
| Customer due diligence (CDD) | Identify and verify buyers and beneficial owners before completing the transaction; EDD for high-risk customers | Federal Decree-Law No. 10 of 2025 and Cabinet Resolution No. 134 of 2025 |
| Sanctions screening | Screen customers against UAE and UN targeted financial sanctions lists | Cabinet Resolution No. 134 of 2025 |
| goAML registration and reporting | Register on goAML and file STR/SAR where suspicion arises; real estate activity reporting for specified transactions (cash ≥ AED 55,000, or virtual-asset involvement) | MoET guidance; goAML portal |
| Record keeping | Five years minimum from transaction completion or relationship end | Federal Decree-Law No. 10 of 2025; Cabinet Resolution No. 134 of 2025 |
| Regulatory inspection readiness | Maintain and produce documentation on MoET request | MoET supervision framework |
The buyer-side reality
Off-plan sales are where developer AML is tested. A buyer paying in cash, through a third party, via virtual assets, or through a structure with unclear beneficial ownership is exactly the pattern the regime targets. Practical controls that pass inspection:
- Verify the buyer's identity and, for corporate buyers, the beneficial owners at the 25% ownership threshold — before the SPA is signed, not at handover.
- Treat payments from parties other than the buyer as a red flag requiring source-of-funds evidence.
- Screen every buyer (individual and corporate) against UAE and UN sanctions lists and keep the screening evidence.
- File through goAML whenever the transaction triggers a report or suspicion arises — filing a report is not an accusation of the customer, it is the legal discharge of your duty.
Escrow and financial controls are part of the same picture
In Dubai, off-plan developer payments must flow through a project-specific escrow account under Law No. 8 of 2007 (Dubai), with each project holding a separate account and funds released against certified construction milestones. Commingling escrow funds with operating cash is both a real-estate-regulatory violation and an AML red flag, because it destroys the audit trail between buyer payments and project use.
Penalties
Administrative fines for AML violations reach into the millions of dirhams under the Cabinet Decision No. 16 of 2021 penalty list (from AED 50,000 per violation, scaling upward), while criminal money-laundering penalties under the 2025 law now reach AED 5 million to AED 100 million for legal persons — or the value of the criminal property, whichever is greater. Licence suspension and, for individuals, imprisonment sit alongside the fines. Supervision is active: the Ministry of Economy runs inspection campaigns on the real estate sector every year and publishes its enforcement statistics.
How Finanshels handles this
We build and run AML programmes for developers: risk assessments, CDD/EDD workflows, sanctions screening, goAML registration and reporting, and inspection-ready record keeping. Talk to our AML team if your programme predates October 2025.
FAQs
Are real estate developers really DNFBPs?
Yes. Developers and brokers who buy and sell real estate for customers fall under the DNFBP category and are supervised for AML purposes by the Ministry of Economy on the mainland.
Which law applies now — the 2018 or 2025 AML law?
Federal Decree-Law No. 10 of 2025, effective 14 October 2025, replaced the 2018 law. Its Executive Regulations, Cabinet Resolution No. 134 of 2025, replaced the 2019 regulations with effect from 14 December 2025.
What transaction triggers a report for a developer?
Suspicion always triggers a STR/SAR through goAML regardless of value. In addition, real estate activity reporting applies to specified transactions including cash payments of AED 55,000 or more and transactions involving virtual assets.
How long must developer AML records be kept?
At least five years from the date the transaction was completed or the business relationship ended, whichever is later, under Federal Decree-Law No. 10 of 2025 and Cabinet Resolution No. 134 of 2025.
Last reviewed: September 2026 by Krishna Subash Nair, Team Lead – AML & Compliance Advisory, Finanshels. Rules as of Federal Decree-Law No. 10 of 2025 and Cabinet Resolution No. 134 of 2025; verify current requirements against MoET (moet.gov.ae) and UAE FIU guidance before acting.
