Do free zone real estate transactions fall under UAE federal AML law?

UAE
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Yes. The federal AML/CFT framework applies across the UAE, including transactions and businesses located in commercial and financial free zones. Federal Decree-Law No. 10 of 2025 and its Executive Regulations set the baseline obligations for all financial institutions and DNFBPs in the State, and real estate activity carried on in a free zone is not exempt from customer due diligence, beneficial ownership, screening, record-keeping and reporting duties.

Some financial free zones, such as the Abu Dhabi Global Market and the Dubai International Financial Centre, have their own regulators that supervise AML compliance within their jurisdictions, but they operate within and are consistent with the federal regime and the standards set by the National Committee. Brokers should confirm which authority supervises them, but in all cases the substantive obligations, including goAML reporting to the federal FIU, continue to apply.

The practical message is that a free zone address does not reduce a real estate business’s AML responsibilities.

Legal Reference (UAE):

For more details, consult the full text of Federal Decree-Law No. 10 of 2025 or seek guidance from your AML compliance officer.

AML regulations for real estate agents in the UAE

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Yes. The Decree-Law is federal legislation that applies across the State, and neither it nor the Executive Regulations carve free zone property out of the definition of a designated non-financial business and profession. A broker or agent concluding a purchase or sale on behalf of a customer is in scope wherever the property sits and wherever the brokerage is licensed.

What changes with location is the supervisory authority, not the obligation. The supervisory authority is the body entrusted with supervising the business under its own legislation, so a mainland brokerage and a free zone brokerage may answer to different regulators while owing the same customer due diligence, record-keeping, screening and reporting duties. Suspicious transaction reports go to the same Financial Intelligence Unit in every case, because reports are submitted to it exclusively.

Legal Reference (UAE):

· Cabinet Resolution No. 134 of 2025, Article 3(2), which defines real estate brokers and agents as DNFBPs without any territorial carve-out for free zones.

· Federal Decree-Law No. 10 of 2025, Article 11, which establishes the Financial Intelligence Unit and provides that all suspicious transaction reports shall be submitted to it exclusively.

For more details, refer to the Executive Regulations or seek guidance from your AML compliance officer.

AML compliance for real estate brokers in the UAE