Is a business-wide risk assessment mandatory for UAE real estate brokers?
Yes. A business-wide, or enterprise-wide, risk assessment is a mandatory foundation of AML compliance for UAE real estate brokers. The firm must identify, understand and document the money laundering, terrorist financing and proliferation financing risks arising from its customers, geographies, products, delivery channels and transaction types, and keep the assessment up to date.
The risk assessment drives the rest of the programme. It determines the intensity of customer due diligence, the design of internal controls, monitoring thresholds and training priorities under a risk-based approach. Brokers must take the national risk assessment into account, review their own assessment when circumstances change, and be able to provide it to the Ministry of Economy and Tourism on request. A programme that is not anchored in a documented risk assessment is a frequent finding in supervisory inspections.
Legal Reference (UAE):
· Federal Decree-Law No. 10 of 2025, Article 19(1)(a) - requires DNFBPs to identify, assess, document and update the risks of the crime and to retain the risk assessment study.
· Cabinet Resolution No. 134 of 2025 (Executive Regulations) - details the risk-based approach requirements.
For more details, consult the Executive Regulations or seek guidance from your AML compliance officer.