Do virtual asset payments in UAE property deals require a REAR regardless of amount?
Yes. Where a real estate purchase or sale is settled wholly or partly using a virtual asset, or where the funds were converted to or from a virtual asset at any point in the funding chain, a Real Estate Activity Report (REAR) must be filed regardless of the amount involved. Virtual asset involvement is a zero-threshold trigger, unlike the AED 55,000 cash threshold.
This means a payment routed through cryptocurrency, or fiat funds that originated from converting crypto, obliges the broker or agent to report the transaction to the UAE Financial Intelligence Unit through goAML. The rationale is that virtual assets carry heightened money laundering and proliferation financing risk because of their speed, cross-border reach and potential anonymity. Firms should ask about the source and payment method early in the transaction and document the answer.
Legal Reference (UAE):
· Real Estate Activity Report (REAR), MoET Circular No. 05/2022, filed via the UAE Financial Intelligence Unit goAML portal - mandates a REAR where the payment method is a virtual asset, or where funds were converted from a virtual asset, for all or part of the property value.
· Federal Decree-Law No. 10 of 2025, Article 18 - reporting of suspicious transactions applies regardless of value.
For more details, consult the full text of Circular No. 05/2022 or seek guidance from your AML compliance officer.