Are off-plan property sales subject to AML rules in the UAE?
Yes. Off-plan property sales fall within the UAE AML framework just as completed property sales do. The broker, agent or developer concluding the sale is acting as a Designated Non-Financial Business and Profession and must apply the full set of preventive measures, including customer due diligence, beneficial ownership identification, ongoing monitoring and reporting.
Off-plan sales can carry heightened risk because payments are often staged over a long construction period and may involve assignments of contracts before completion. Brokers should verify the buyer and any beneficial owner at the outset, monitor staged payments, and file a Real Estate Activity Report where physical cash of AED 55,000 or more, or virtual assets, are used. Suspicion at any stage triggers a Suspicious Transaction Report.
Legal Reference (UAE):
· Federal Decree-Law No. 10 of 2025, Article 19 — DNFBPs must apply CDD, ongoing monitoring and record-keeping across their business.
· MoE Circular No. 5/2022 — REAR triggers apply to cash and virtual-asset payments in freehold transactions.
For more details, consult the full text of Federal Decree-Law No. 10 of 2025 or seek guidance from your AML compliance officer.
A deep dive into AML compliance for the UAE real estate sector