How should a UAE real estate broker conduct an Enterprise-Wide Risk Assessment?
A UAE real estate broker must conduct, document and periodically update an Enterprise-Wide Risk Assessment (EWRA) that identifies and evaluates the firm’s exposure to money laundering, terrorism financing and proliferation financing. The EWRA must be tailored to the firm’s actual business and approved by senior management. It is the foundation for every other control, from CDD intensity to monitoring rules.
The assessment must analyse risk across at least five dimensions: customer profile (corporates, individuals, PEPs, non-residents), product or service (off-plan, secondary market, freehold, leasehold, virtual-asset settlement), geography (issuing country of buyer, location of property, source of funds jurisdiction), delivery channel (face-to-face, remote onboarding, agency chains), and transaction characteristics (cash component, high value, rapid resale). The output must be a documented risk rating per dimension and at firm level, with mitigating controls aligned to each high-risk driver. The EWRA should be refreshed at least annually and after any material change such as a new product, expansion to a new jurisdiction, or a finding from the National Risk Assessment.
Legal Reference (UAE):
- Federal Decree-Law No. 10 of 2025, Article 19 requires DNFBPs to operate a risk-based approach.
- Cabinet Resolution No. 134 of 2025, Article 5 imposes risk identification, assessment and mitigation duties.
- Cabinet Resolution No. 71 of 2024 fines failure to assess risk from AED 50,000 to AED 500,000.
For more details, consult the full text of Cabinet Resolution 134 of 2025
AML compliance requirements for the real estate sector in the UAE