How should a UAE real estate broker handle a property purchase paid in cryptocurrency?
When a freehold property in the UAE is paid for using a virtual asset, or with funds that were converted from a virtual asset, the broker must file a Real Estate Activity Report (REAR) through goAML for all or part of the property value. This applies regardless of the cash threshold, because virtual asset payments carry heightened traceability and money laundering risk.
Beyond reporting, the broker should apply enhanced due diligence, take reasonable steps to establish the source of the virtual assets and the identity of the beneficial owner, and satisfy itself that the funds are traceable. Where the source cannot be verified or suspicion arises, a suspicious transaction report should be filed in addition to the REAR.
Legal Reference (UAE):
· MOE Circular No. 5/2022 on the Real Estate Activity Report - makes virtual asset payments and virtual asset conversions reportable via REAR.
· Cabinet Resolution No. 134/2025 (Executive Regulations), Article 5 - requires enhanced measures to manage higher-risk transactions.
For more details, consult the full text of MOE Circular 5/2022 or seek guidance from your AML compliance officer.