Are real estate agents and brokers considered DNFBPs under UAE AML law?
Yes. Real estate agents and brokers are classified as Designated Non-Financial Businesses and Professions (DNFBPs) whenever they carry out, or arrange, transactions for the purchase and sale of real property on behalf of a client. This classification brings them squarely within the UAE’s AML/CFT preventive framework, on the same footing as financial institutions for the core compliance duties.
As DNFBPs, real estate agents and brokers must conduct a business risk assessment, apply customer due diligence, screen against sanctions lists, keep records, register on goAML, and report suspicious transactions. The obligation applies regardless of the firm’s size, and covers both sale and purchase mandates. Firms licensed and operating from DIFC or ADGM are supervised by those free-zone authorities instead.
Legal Reference (UAE):
· Federal Decree-Law No. 10 of 2025, Article 19 - sets out the preventive obligations (risk assessment, CDD, record-keeping, internal controls) that DNFBPs, including real estate brokers, must implement.
· Federal Decree-Law No. 10 of 2025, Article 20 - prohibits carrying on a DNFBP activity without registration or enrolment with the competent authority.
For more details, consult the full text of Federal Decree-Law No. 10 of 2025 or seek guidance from your AML compliance officer.