Does the AED 55,000 REAR threshold apply to the property value or the cash payment?
The AED 55,000 threshold applies to the cash or virtual-asset payment, not to the total value of the property. If a buyer pays AED 55,000 or more in physical cash toward a freehold property, a Real Estate Activity Report is triggered even when that cash is only a partial payment and the rest is settled by bank transfer. A multi-million dirham property paid entirely by traceable bank transfer, with no cash element, does not trigger a REAR.
Brokers should aggregate cash payments connected to the same transaction rather than viewing each instalment in isolation, since the threshold can be reached across several physical cash payments. Any payment in virtual assets, or funds converted from virtual assets, triggers a REAR regardless of value.
Legal Reference (UAE):
· MoE Circular No. 5/2022 — the threshold is tied to a single or several physical cash transactions equal to or exceeding AED 55,000 for all or part of the property value.
· Federal Decree-Law No. 10 of 2025, Article 19 — obligation to monitor and record transactions.
For more details, consult the full text of MoE Circular No. 5/2022 or seek guidance from your AML compliance officer.
A deep dive into AML compliance for the UAE real estate sector