Does a UAE real estate broker need an appointed AML compliance officer?
Yes. A UAE real estate broker must appoint a suitably qualified AML compliance officer, often called the Money Laundering Reporting Officer, to oversee the firm’s AML/CFT programme. This individual is the focal point for compliance and the liaison with the Ministry of Economy and Tourism and the Financial Intelligence Unit.
The compliance officer’s duties include implementing and maintaining internal policies and controls, reviewing internal escalations of unusual activity, deciding whether to file a REAR, STR or other report through goAML, and keeping a record of the rationale for filing decisions. The officer should have sufficient seniority, independence and access to information to carry out the role effectively, and the firm should ensure adequate resourcing and staff training so that front-line staff know how to escalate concerns.
Legal Reference (UAE):
· Federal Decree-Law No. 10 of 2025, Article 19(1)(d) - requires DNFBPs to establish internal policies, controls and procedures approved by senior management.
· Cabinet Resolution No. 134 of 2025 (Executive Regulations) - specifies the compliance officer appointment and functions.
For more details, consult the Executive Regulations or seek guidance from your AML compliance officer.