Must a real estate broker file an STR even if the deal is below AED 55,000?
Yes. The duty to file a Suspicious Transaction Report (STR) is entirely separate from the AED 55,000 REAR threshold and applies regardless of the transaction value. If a real estate broker suspects, or has reasonable grounds to suspect, that funds are proceeds of crime or are linked to money laundering or terrorist financing, it must report to the FIU without delay, even if the amount is small or the transaction was never completed.
This means a low-value deal, a cancelled transaction, or an attempted transaction can all require an STR if suspicion exists. The REAR captures objective cash and virtual asset thresholds; the STR captures suspicion. A broker should never treat being below AED 55,000 as a reason not to report a suspicious matter, and must not tip off the customer that a report has been made.
Legal Reference (UAE):
· Cabinet Resolution No. 134/2025 (Executive Regulations), Article 18 - requires reporting of suspicion regardless of the transaction value.
· Cabinet Resolution No. 134/2025 (Executive Regulations), Article 19 - prohibits tipping off the customer about a report.
For more details, consult the full text of the Executive Regulations or seek guidance from your AML compliance officer.