How long must UAE real estate brokers keep AML transaction records?
UAE real estate brokers must retain all records, documents, instruments and data relating to their financial and cash transactions and business dealings for a period of not less than five years. The five-year period runs from the date the transaction is completed or the business relationship with the customer is terminated, whichever applies.
Records that must be kept include customer identification and CDD files, beneficial ownership information, transaction and payment records, and copies of any reports filed with the FIU. These records must be made available promptly to the competent authorities on request. Good record-keeping is not just a legal duty; it is what allows a broker to demonstrate that its compliance programme was actually followed if it is ever audited or investigated.
Legal Reference (UAE):
· Cabinet Resolution No. 134/2025 (Executive Regulations), Article 25 - requires retention of records for at least five years from completion of the transaction or end of the relationship.
· MOE Circular No. 1/2021 - reinforces record-keeping obligations for real estate brokers and agents.
For more details, consult the full text of the Executive Regulations or seek guidance from your AML compliance officer.