Do free zone real estate companies have to comply with UAE AML rules?
Yes. Real estate brokers and agents operating in the UAE’s commercial free zones are subject to the same AML/CFT obligations as those on the mainland. The Ministry of Economy’s supervision of the real estate sector expressly extends to entities operating in commercial free zones, so a free zone licence does not exempt a brokerage from the framework.
Free zone real estate firms must therefore register on goAML, appoint a compliance officer, apply customer due diligence, identify beneficial owners, screen for sanctions, keep records for at least five years, and file REARs and STRs where the triggers are met. The Ministry has specifically reminded brokers and agents in free zones of their five-year record-keeping duty.
Legal Reference (UAE):
· MoE Circular No. 1/2021 — supervision covers DNFBPs operating in the State including those in commercial free trade zones.
· Federal Decree-Law No. 10 of 2025, Article 20 — registration or enrolment is required to carry on a DNFBP activity.
For more details, consult the full text of MoE Circular No. 1/2021 or seek guidance from your AML compliance officer.