How long must UAE real estate firms keep AML records?
UAE real estate firms must keep AML records for at least five years. This retention period applies to customer identification and due diligence records, transaction records, correspondence, and the supporting documentation behind any report filed with the Financial Intelligence Unit. The five-year clock generally runs from the end of the business relationship or the date the transaction was completed.
Records must be kept in a form that allows them to be produced promptly to the competent authorities on request, so that a transaction can be reconstructed if needed for investigation or supervision. Where an investigation is ongoing, the supervisor may require records to be retained for longer. Firms should maintain an organised, retrievable archive rather than relying on scattered files, and ensure that records survive staff changes and system migrations.
Legal Reference (UAE):
· Federal Decree-Law No. 10 of 2025, Article 19(1)(f) - requires DNFBPs to retain all records, documents and data relating to transactions and ensure their immediate availability to competent authorities.
· Cabinet Resolution No. 134 of 2025 (Executive Regulations) - specifies the minimum five-year retention period.
For more details, consult the Executive Regulations or seek guidance from your AML compliance officer.