Do real estate agents in the UAE need to appoint an AML compliance officer?
Yes. Every licensed real estate brokerage in the UAE must appoint an AML compliance officer (often acting as the Money Laundering Reporting Officer) with enough seniority and independence to run the firm’s day-to-day AML programme and to report suspicions without internal interference. This person is the firm’s primary point of contact with the Financial Intelligence Unit and is responsible for filing reports on the goAML portal.
The compliance officer’s duties include overseeing customer due diligence, maintaining the firm’s risk assessment, delivering staff training, keeping records, and deciding whether to submit Suspicious Transaction Reports. The appointment should be documented in the firm’s internal AML policies, which must be approved by senior management.
Legal Reference (UAE):
· Federal Decree-Law No. 10 of 2025, Article 19 — requires regulated entities to establish internal policies and controls approved by senior management to manage and mitigate ML/FT risk.
· MoE Circular No. 1/2021 — directs real estate brokers to appoint a compliance officer.
For more details, consult the full text of Federal Decree-Law No. 10 of 2025 or seek guidance from your AML compliance officer.