Are real estate developers considered DNFBPs under UAE AML law?
Real estate brokers and agents are expressly designated as DNFBPs under UAE AML law when they conclude transactions or settlements on behalf of customers relating to the purchase or sale of real estate. Developers who market and sell property, or who use brokers and agents for that purpose, are drawn into the same AML/CFT framework because the underlying property transactions are subject to reporting and due diligence.
In practice, any party facilitating a freehold sale or purchase should assess whether it is performing a DNFBP activity and, if so, apply customer due diligence, monitor for suspicious activity, and file Real Estate Activity Reports where thresholds are met. The safest course for a developer sales function is to operate a full AML programme aligned with broker obligations.
Legal Reference (UAE):
· Cabinet Resolution No. 134/2025 (Executive Regulations), Article 3(2) - defines real estate brokers and agents concluding property transactions as DNFBPs.
· Federal Decree-Law No. 10/2025, Article 4 - establishes criminal liability of legal persons where an offence is committed in their name or for their account.
For more details, consult the full text of the Executive Regulations or seek guidance from your AML compliance officer.