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Anti-Money Laundering (AML & CFT)

Anti Money Laundering – (Real Estate Agents and Brokers) Designated Non-Financial Businesses and Professionals (DNFBP)


UAE Federal Law No 20 of 2018 on Anti Money Laundering (AML) was introduced in the UAE for combating financing terrorism and illegal organization. The law enforced responsibilities on DNFBP to tackle Money Laundering. DNFBP includes Broker and Real Estate Agent, Dealers in Precious Metal and precious stones, Legal professionals, Independent accountants and provider of corporate services and trusts.

Duties and responsibilities of DNFBP: Appointment of a compliance officer, Performance of customer due diligence (CDD), Conducting screening for existing and new customers, Suspicious Transaction Report (STR) to the Financials Intelligence Unit (FIU), Keeping records for Five years, ensure all compliance related to AML. To fulfill the compliances, DNFBPs should ensure that they have adequate internal policies, procedures and controls in place.

Procedures for Real estate agents and Brokers in Dubai, UAE

Purchase and Sale of Real Estate Freehold Property in UAE through a single cash transaction or several cash transactions amount equal or more AED. 55,000. / Payment by a virtual asset / Funds used to carry out the transaction for the entire, or a portion, of the property value:

Need to receive & Submit :

  1. Emirate ID ‘or’ Passport, Receipts, Invoices, contracts, and Sales Purchase Agreement.
  2. If the Buyer or seller legal person then Trade License, AOA, Real Beneficiary owners, Emirate ID, and passport of owners/shareholders.
  3. Submit a “Real Estate Transaction Report” (“REAR”) to FIU through the GOAML platform.
  4. REAR report in additional submission to STR and other compliances report.
  5. Documents need to maintain a minimum of Five years.

Red Flag – Real estate agents and Brokers in Dubai, UAE

“Red Flag is an indication that Pinpoints involvement of any fraud or suspicious activities in a financial transaction”

Below few Red Flags in Real Estate Transactions:

  1. Agent of Buyer / Seller in transaction unlicensed.
  2. Suspicious nature/behavior of a customer
  3. Loan payment from someone other than the borrower
  4. Buyers make unusual requests
  5. Concealment of the Real beneficiary owner
  6. Submit invalid documents
  7. Payment from an unusually large number of borrowers
  8. Low appraisal value, non-arm length relationship between Buyer and Seller
  9. Past misrepresentation made by seller and buyer
  10. Hide the true value of the asset in order to qualify loan etc.

If you are looking for Anti Money Laundering (AML) Registration, customer due diligence support, Suspicious
Transaction report (STR) to Financials Intelligence Unit (FIU) etc., related to DBFBPS please contact us.:
Singiri & Co., Dubai, UAE. 00971 589 320 410 / 411