Are off-plan property sales subject to AML reporting in the UAE?
Off-plan property sales in the UAE fall within the AML framework because they are freehold sale and purchase transactions concluded on behalf of customers. Brokers and agents involved in off-plan deals must perform customer due diligence, identify beneficial owners, monitor for suspicious activity, and file a Real Estate Activity Report (REAR) where a qualifying cash or virtual asset payment is made.
Off-plan sales can carry particular risk because payments are often staged over time, which can be used to structure cash below thresholds, and because buyers may resell contracts before completion. Brokers should aggregate linked payments when assessing the AED 55,000 cash trigger and remain alert to rapid flipping or third-party payers as potential red flags.
Legal Reference (UAE):
· MOE Circular No. 5/2022 on the Real Estate Activity Report - applies REAR reporting to freehold sale and purchase transactions, including staged payments.
· Cabinet Resolution No. 134/2025 (Executive Regulations), Article 3(2) - brings real estate brokers concluding such transactions within the DNFBP regime.
For more details, consult the full text of MOE Circular 5/2022 or seek guidance from your AML compliance officer.