Property developers in the UAE carry AML obligations where they engage in real estate brokerage or agency activity that brings them within the DNFBP framework. When a developer sells freehold units directly to buyers, it is performing the kind of real estate activity that triggers customer due diligence, record-keeping and reporting duties.
In practice this means developers must identify and verify their buyers, look through corporate purchasers to the beneficial owner, screen against sanctions and PEP lists, and keep records for at least five years. Where a direct sale is settled with cash of AED 55,000 or more, with virtual assets, or with funds converted from virtual assets, the developer must file a Real Estate Activity Report through goAML, just as a broker would. Developers should appoint a compliance officer, run a business risk assessment, and report suspicious transactions. The obligation follows the activity, so developers cannot assume they are outside scope simply because they are not a traditional brokerage.
The DNFBP category for property covers real estate brokers and agents concluding transactions or settlements on behalf of their customers. A developer selling units from its own stock is dealing on its own account rather than acting on behalf of a customer, so it does not fall within that limb of the definition on the wording of the Executive Regulations. That is a narrower answer than most developers should rely on in practice.
Three things pull developers back in. First, a developer that also brokers resales or acts for other owners is acting as an agent for those deals and is in scope for them. Second, the supervisory authority may extend the DNFBP list to other businesses or professions by resolution, in coordination with the National Committee, and developers have been treated as within the reporting perimeter in practice. Third, no one may deal in criminal proceeds, and the targeted financial sanctions freezing duty binds any person, not only DNFBPs. The sensible position is to run a full AML programme and confirm your specific status with your supervisory authority.
· Cabinet Resolution No. 134 of 2025, Article 3(6), which allows other businesses or professions to be brought within the DNFBP definition by resolution of the supervisory authority in coordination with the National Committee.
· Cabinet Resolution No. 74 of 2020, Article 15, under which the obligation to freeze funds of listed persons without delay applies to any person, not only to regulated businesses.
For more details, refer to the Executive Regulations or seek guidance from your AML compliance officer.