The United Arab Emirates has initiated a strict "zero-tolerance" enforcement model for Anti-Money Laundering (AML) compliance as of 2025. Following the UAE's removal from the FATF Grey List in April 2024, the Ministry of Economy has intensified scrutiny on Designated Non-Financial Businesses and Professions (DNFBPs), with Real Estate agents being a primary target.
The New Penalty Landscape
Under Federal Decree-Law No. (10) of 2025 (and amendments to Law No. 20 of 2018), administrative fines have surged. The days of minor warnings are over; inspectors are now authorized to issue immediate fines for "technical" non-compliance.
Critical Fines to Watch:
- AED 50,000 to 100,000: Failure to register on the goAML portal.
- AED 50,000: Failure to appoint a qualified Compliance Officer / MLRO.
- AED 200,000 - 5,000,000: Failure to report suspicious transactions (STRs) when there are reasonable grounds to suspect illicit funds.
- License Revocation: Repeated violations can lead to the freezing of trade licenses and blacklisting of directors.
Specific Obligations for Real Estate
Brokers and developers must now perform Enhanced Due Diligence (EDD) on all high-risk customers, including Politically Exposed Persons (PEPs) and foreign investors from high-risk jurisdictions.
- Cash Threshold Reporting: Any cash transaction (or virtual asset transaction) equal to or exceeding AED 55,000 must be reported via a Real Estate Activity Report (REAR).
- Source of Funds: You are legally required to verify where the money is coming from. A simple bank transfer receipt is no longer sufficient proof of legitimacy.
- UBO Identification: You must identify the Ultimate Beneficial Owner—the actual human being behind any corporate buyer.
Managerial Liability
Crucially, the new laws pierce the corporate veil. Managers and MLROs can be held personally liable for the firm's failure to report suspicions. Penalties include imprisonment and personal fines up to AED 5 million if it is proven you "should have known" about the illicit nature of a deal.
Author: Zeej Strategic Consulting Research Team