Does a REAR need to be filed if payment comes from someone other than the buyer?
Payment by a third party is a well-recognised red flag in real estate and should trigger careful scrutiny. Where a qualifying cash payment of AED 55,000 or more, or any virtual asset payment, is made by a person other than the named buyer, the transaction still falls within the Real Estate Activity Report (REAR) triggers and should be reported to the Financial Intelligence Unit through goAML.
Third-party funding can be legitimate, for example a family gift or a corporate purchase, but the broker must establish and document who is really providing the funds and why. If the arrangement cannot be satisfactorily explained, or if it appears designed to obscure the true source of funds, the firm should also consider filing a Suspicious Transaction Report. The two reports are not mutually exclusive.
Legal Reference (UAE):
· Real Estate Activity Report (REAR), MoET Circular No. 05/2022, filed via the UAE Financial Intelligence Unit goAML portal - sets the REAR triggers for qualifying cash and virtual asset payments in freehold transactions.
· Federal Decree-Law No. 10 of 2025, Article 18 - requires reporting where there are reasonable grounds to suspect a transaction is linked to crime.
For more details, consult the full text of Circular No. 05/2022 or seek guidance from your AML compliance officer.