Are off-plan and property developer sales subject to UAE AML obligations?
Yes. Property developers selling directly to buyers, including off-plan sales, fall within the UAE AML/CFT framework as DNFBPs when they carry out the purchase and sale of real estate. Developers must therefore apply the same core preventive measures as brokers: registration on goAML, customer due diligence, beneficial owner identification, sanctions screening, record-keeping and reporting.
Off-plan and developer sales can carry particular risk because they may involve staged payments over time, large sums, corporate or offshore buyers, and payment methods that include cash or virtual assets. Where a qualifying cash payment of AED 55,000 or more, or any virtual asset payment, is made directly to a developer, a Real Estate Activity Report is required through goAML. Developers should integrate AML checks into their sales and collections processes rather than treating them as a broker-only concern.
Legal Reference (UAE):
· Federal Decree-Law No. 10 of 2025, Article 19 - imposes the preventive obligations on DNFBPs carrying out real estate transactions.
· Real Estate Activity Report (REAR), MoET Circular No. 05/2022, filed via the UAE Financial Intelligence Unit goAML portal - applies the REAR triggers to freehold purchase and sale transactions.
For more details, consult the MoET real estate guidance or seek guidance from your AML compliance officer.