Real estate brokers in the UAE are Designated Non-Financial Businesses and Professions (DNFBPs), and since 14 October 2025 their anti-money laundering obligations run under Federal Decree-Law No. (10) of 2025, which replaced the 2018 AML law. The right consultant is not the one that sells you a policy folder. It is the one that maps your brokerage's real exposure, registers you with the Ministry of Economy and on goAML, builds customer due diligence into your deal flow, and keeps the programme alive through reviews and inspections. This guide sets out the 2026 legal baseline for brokerages, what a competent consultant must deliver, and how to choose one.
Who must comply: brokers as DNFBPs
Every real-estate broker and agent registered and licensed in the UAE — including brokerages licensed in free zones — falls in scope as a DNFBP. The Ministry of Economy is the supervisory authority for the sector; brokers operating from the DIFC and ADGM financial centres are supervised there instead. The Ministry has been actively regulating this sector for years — for example, it has obligated brokers and agents to retain records and transaction data for at least five years (Ministry of Economy circular).
The 2026 legal baseline for brokerages
Four instruments define what a brokerage must do in 2026:
- Federal Decree-Law No. (10) of 2025 — the new AML law, in force since 14 October 2025, replacing Federal Decree-Law No. (20) of 2018. It keeps the core duties (risk assessment, customer due diligence, beneficial-owner identification, suspicious transaction reporting, record-keeping, training) and strengthens enforcement powers. Text: Federal Decree-Law No. 10 of 2025 on the UAE Legislation portal.
- Cabinet Resolution No. (134) of 2025 — the executive regulations issued on 29 October 2025, which entered into force 30 days after Official Gazette publication and detail how DNFBPs apply due diligence, reporting and record-keeping duties. Text: Cabinet Resolution No. 134 of 2025.
- The AED 55,000 reporting threshold — where any part of a property's value is settled in physical cash or virtual assets and the amount reaches AED 55,000 or more, the transaction must be reported to the authorities. Brokers have carried this duty since the Ministry of Economy and Ministry of Justice reporting circular took effect in July 2022.
- goAML registration — suspicious transaction reports are filed electronically on the goAML platform, and registration on it is mandatory for DNFBPs.
What your AML programme must include in 2026
| Programme component | What it means for your brokerage | Legal anchor |
|---|---|---|
| Enterprise-wide risk assessment | Documented, refreshed at least annually, covering buyer nationalities, payment methods, off-plan and secondary sales | Federal Decree-Law No. 10 of 2025 |
| Customer due diligence | Verify each buyer's identity and (for companies) licence and beneficial owners, before or during the transaction | Cabinet Resolution No. 134 of 2025 |
| Enhanced due diligence | Deeper checks where the buyer, funding route or jurisdiction is higher-risk | Cabinet Resolution No. 134 of 2025 |
| Cash and virtual-asset reporting | Report any deal settled partly or wholly in cash or virtual assets of AED 55,000 or more | Ministry of Economy AML circulars |
| Suspicious transaction reports | File on goAML promptly; never tip off the customer | Federal Decree-Law No. 10 of 2025 |
| Record-keeping | Keep transaction records and CDD files for at least five years | Ministry of Economy circular |
| Staff training | Ongoing AML training for agents and back office | Federal Decree-Law No. 10 of 2025 |
What a competent AML consultant actually delivers
- A brokerage-specific risk assessment — built from your actual deal types, buyer mix and payment flows, not a recycled template.
- goAML registration and a filing workflow — your entity registered correctly under the Ministry of Economy, and named staff who know how to draft and submit a report.
- Due diligence embedded in deal flow — CDD steps placed inside your listing-to-closing process, so compliance happens at the moment of the transaction, not after it.
- Inspection readiness — your records, policies and training log organized so a Ministry of Economy review finds a programme, not a scramble.
- A review cadence — the programme re-checked after the new executive regulations and at least annually.
How to choose: five checks before you sign
Ask each candidate consultancy:
- Which supervisory authority will you register us under, and have you done this for brokers specifically?
- How will CDD fit into our deal timeline without stalling transactions?
- Who drafts and files reports on goAML when we have a suspicious case?
- How are you tracking the transition from the 2018 framework to Federal Decree-Law No. 10 of 2025 and Resolution 134 of 2025?
- What does the annual refresh include, and who signs it off?
A consultant who cannot answer in specifics is selling a document. For the general market view, see our guide to AML compliance consultants in the UAE.
FAQs
Are free-zone real estate brokers covered?
Yes. The Ministry of Economy's obligations apply to brokers and agents registered and licensed in the UAE, including free zones; DIFC and ADGM brokers fall under their own financial-centre supervisors.
What triggers a suspicious transaction report?
Suspicion, not a fixed amount: unexplained source of funds, a buyer reluctant to identify beneficial owners, or a transaction with no apparent economic purpose. The AED 55,000 figure is a separate reporting threshold for cash or virtual-asset settlement.
Who is our supervisory authority?
The Ministry of Economy, unless your brokerage is licensed in DIFC or ADGM.
What happens if we are not registered on goAML?
Registration is mandatory for DNFBPs. Failing to register, and failing to file required reports, carry administrative penalties under the AML framework — and the underlying transaction records do not cure the breach.
Reviewed by Krishna Subash Nair — Finanshels AML & compliance specialist. Last reviewed: 4 October 2026. This article is general information, not legal advice; confirm your position against the cited instruments.
