AML/CFT in UAE real estate : a practical playbook for compliance and risk

Following the UAE’s FATF grey list exit in 2024, antimoney laundering and counterterrorist financing (AML/CFT) expectations have tightened across the real estate value chain. Based on the source “AntiMoney Laundering in UAE and KSA Real Estate: Strategic Compliance Across Jurisdictions and CrossBorder Risk Interfaces” (STA Law Firm, Aug 2025), this article provides an operational roadmap for developers, funds and intermediaries active in the UAE.

Legal framework and oversight

The UAE framework centres on Federal DecreeLaw No. 20 of 2018 (AML/CFT), its Implementing Regulations (Cabinet Decision No. 10/2019) and DNFBP requirements. The Ministry of Economy and the FIU oversee compliance, with sectoral supervision from the Dubai Land Department (DLD) and RERA. Firms must apply a risk based approach (RBA) covering customers, products, channels and geographies.

Scope and extraterritorial reach

AML duties cover sales/purchases, longterm leases and real estate backed financings, including through freezone structures (DIFC/ADGM) where a mainland nexus exists. High value deals and complex ownership (SPVs, nominees, trusts) attract heightened scrutiny.

Core compliance pillars

• Business Risk Assessment (BRA): map products/clients/countries; review annually and on events.
• KYC/CDD/EDD: verify natural persons (passport/Emirates ID) and corporates (constitutional docs; authorised signatories); trace the UBO.
• PEPs & sanctions: realtime screening (national/UN lists); EDD and senior approval for PEPs.
• Transaction monitoring: alert scenarios; investigate anomalies; document rationales.
• Reporting: timely STR/SAR via goAML; no tipping
• Record keeping: retain CDD, transaction and decision records per statutory periods.
• Internal controls: empowered AMLCO, policies/procedures, continuous training and independent audit.

Real estate specific pressure points

• Opaque structures (SPVs, nominees, offshore chains): robust UBO and source offunds/wealth
• Offplan/presales: escrow strictures; realtime oversight; milestone based drawdowns.
• Split payments or third party payers: watch for threshold circumvention and structuring.
• Luxury assets: systematic EDD (background, lifestyle, bank/tax evidence).
• Proptech/tokens: pseudonymity and velocity risks; align AML with PDPL (data) and virtual asset rules (VARA/DFSA/FSRA).

Case study : acquisition via SPV

A fund acquires a UAE commercial property via a DIFC SPV with local bank financing. The transaction triggers exhaustive KYC/UBO by the DNFBP (broker/developer), bank flow reviews and sanctions checks. Coordination between bank, conveyancer and agent is essential to avoid blind spots and ensure fast STR filing upon red flags.

Operationalising compliance

1. Onboarding & screening: structured questionnaires; documentary trails (income, assets, tax); continuous monitoring.
2. Cash policy: strict limits; internal thresholds; detect staged payments.
3. Sanctions & PEPs: embed tools; manage false positives; AMLCO escalation.
4. Governance: risk committees; board reporting; periodic external audits.
5. RegTech: AI/ML monitoring; automated UBO screening; workflowed STRs.

Enforcement and penalties

Noncompliance can lead to heavy administrative fines, licence suspensions, freeze orders and criminal action. Authorities (MoE, DLD/RERA, prosecution) have intensified thematic reviews and visits. Missing BRA, weak training, absent written policies or incomplete KYC files are red flag defects.

In real estate, AML/CFT is a precondition for transaction certainty and reputation. A risk based, well documented and auditable programme (KYC/UBO, monitoring, reporting and governance) reduces exposure and supports sustainable growth.

Our lawyers, who are experts in business law, are available to answer all your questions and provide advice. We offer face-to-face meetings or videoconferencing. You can make an appointment directly online at https://www.agn-avocats.fr/.

AGN AVOCATS – Business Law
contact@agn-avocats.fr
09 72 34 24 72