Must UAE real estate brokers carry out an enterprise-wide risk assessment?
Yes. Every UAE real estate brokerage must identify, assess, document and keep up to date the money laundering, terrorist financing and proliferation financing risks across its business. This enterprise-wide risk assessment (EWRA) considers risks linked to the firm’s customers, the countries and geographies it deals with, the products and services it offers, and its delivery channels.
The EWRA underpins the risk-based approach: it tells the firm where to apply standard, simplified or enhanced due diligence and how to allocate its compliance resources. Brokers must take account of the findings of the UAE national risk assessment, retain the study and supporting information, and provide it to the Ministry of Economy on request. The assessment should be reviewed regularly and whenever the business changes.
Legal Reference (UAE):
· Federal Decree-Law No. 10 of 2025, Article 19 — firms must identify, assess, document and update their ML/FT risks using a risk-based approach.
· Cabinet Resolution No. 134 of 2025, Article 4 — CDD and risk mitigation must reflect the firm’s risk assessment.
For more details, consult the full text of Federal Decree-Law No. 10 of 2025 or seek guidance from your AML compliance officer.
A deep dive into AML compliance for the UAE real estate sector