The UAE real estate market attracts global buyers. The market moves large sums across borders. Criminals target big transactions for illicit flows. The government builds strict AML rules to stop abuse. Real estate firms must follow these rules with care. This guide explains the duties in simple words.
Why AML Compliance Matters in Property Deals
Money laundering hurts trust in markets. Dirty funds distort prices and risks. AML controls protect investors and tenants. AML controls protect developers and agents. Strong compliance supports banks and regulators. A firm with clean records earns better partnerships.
Who Must Comply inside Real Estate
Designated Non-Financial Businesses and Professions must comply. Brokers must comply. Agents must comply. Developers must comply. Leasing offices must comply. Property managers must comply. Each party must run checks on customers. Each party must file reports when red flags arise.
Legal Frame in Plain Words
Federal Decree-Law No. 20 of 2018 sets the base. Cabinet and ministry decisions add detail. The rules define crimes and red flags. The rules define duties for DNFBPs. Firms must keep records for set years. Firms must train staff and test controls.
Core AML Program: The Six Pillars
- Governance and Policies
You appoint a compliance officer with authority. You approve an AML policy and procedures. You review the policy each year. - Risk Assessment
You score risk by customer, geography, product, and channel. You update scores when facts change. - Customer Due Diligence (CDD/KYC)
You verify identity with reliable documents. You identify beneficial owners for entities. You understand source of funds for higher risk. - Enhanced Due Diligence (EDD)
You apply extra checks to PEPs and high-risk cases. You seek senior approval before onboarding. - Monitoring and Screening
You monitor transactions with set rules. You screen names against sanctions and watchlists. You record alerts and outcomes. - Reporting and Recordkeeping
You file Suspicious Transaction Reports when needed. You store records for at least five years. You secure evidence for inspections.
CDD Steps for Property Firms
- Collect ID, visa, and contact data from the buyer or tenant.
- Obtain trade license and ownership proof for companies.
- Identify and verify beneficial owners behind entities.
- Check source of funds for deposits and balances.
- Match names against sanctions and adverse media.
- Re-verify when a risk trigger appears in the file.
Red Flags You Should Watch
- A buyer pays large amounts in cash.
- A client uses many third-party payers with no link.
- A company with weak purpose buys high-value villas.
- Funds flow from high-risk locations without logic.
- A client resells units quickly with unusual terms.
- A party refuses to share basic documents.
Recordkeeping Made Simple
You index files by client and property. You store KYC forms with dates and signatures. You keep contracts, invoices, and bank proofs. You archive STR acknowledgments from the system. You protect files with access controls. You retain files for five years from the last activity.
Training and Testing
You run induction training for new hires. You refresh training each year with case studies. You test staff with short quizzes. You document attendance and scores. You audit the AML program each year. You fix gaps with dated action plans.
Technology that Helps
- Digital KYC with ID verification tools.
- Sanctions screening with daily list updates.
- Deal-flow systems with risk scoring fields.
- Alert dashboards for STR preparation.
- Secure document rooms for evidence.
Penalties for Non-Compliance
The authority can impose fines. The authority can suspend licenses. The authority can refer cases for prosecution. Firms can face reputational loss. Firms can lose banking lines. Good programs prevent these outcomes.
Practical Checklist for a Property Deal
- Confirm client identity and beneficial owners.
- Verify source of funds before contract signing.
- Screen names at onboarding and before closing.
- Monitor payments and unusual refunds.
- Document all reviews and approvals.
- Prepare the file for audit or inspection.
What to Do After a Red Flag
You pause the process where allowed by law. You escalate to the compliance officer. You gather facts and documents. You assess the scenario with your risk matrix. You file an STR if suspicion remains. You keep the file confidential and secure.
How to Embed AML in Daily Work
You place CDD steps inside sales workflows. You add risk fields to CRM stages. You require approvals in the deal checklist. You set alerts for high-risk geographies. You log reasons when you approve or decline a client. You review metrics in monthly compliance meetings.
What We Can Help With — Mubarak Al Ketbi (MAK) Auditing
We build your AML policy with UAE rules. We design risk scoring that fits real estate flows. We deploy KYC forms with simple language. We train teams with live cases from property deals. We test files and report gaps with fixes. We prepare you for inspections with tidy evidence. We stand beside your leaders during change because when push comes to shove, we help you stay compliant and confident.
Visit or Contact
- For more information, visit our office: Saraya Avenue Building – Office M-06, Block/A, Al Garhoud – Dubai – United Arab Emirates
- Call / WhatsApp: +971 50 276 2132
