Are off-plan property sales subject to AML rules in the UAE?
Yes. The obligation attaches to the activity, not to the stage of construction. A real estate broker or agent is a designated non-financial business and profession when it concludes transactions or settlements on behalf of a customer in relation to the purchase or sale of real estate, and an off-plan unit is real estate for this purpose. The full set of customer due diligence, record-keeping and reporting duties therefore applies from the moment the broker acts on the deal.
Off-plan carries its own risk profile that the broker’s assessment should recognise. Payments are staged over a long construction period, which gives a buyer repeated opportunities to introduce funds from different sources, and assignment of the contract before handover allows a unit to change hands several times without a title transfer. If the transaction or the funds give reasonable grounds for suspicion, the report goes to the Financial Intelligence Unit immediately, whatever the completion status of the building.
Legal Reference (UAE):
· Cabinet Resolution No. 134 of 2025, Article 3(2), which brings real estate brokers and agents into the DNFBP definition when they conclude transactions on behalf of customers relating to the purchase or sale of real estate.
· Federal Decree-Law No. 10 of 2025, Article 18, which requires immediate notification of the Financial Intelligence Unit where there is suspicion, regardless of the value of the transaction.
For more details, refer to the Executive Regulations or seek guidance from your AML compliance officer.