What AML policies and internal controls must a UAE real estate brokerage have in place?
A UAE real estate brokerage must maintain internal AML/CFT policies, controls and procedures that are approved by senior management and proportionate to the money laundering risks and the size of its business. These must be reviewed and updated on an ongoing basis to remain effective as risks evolve.
At a minimum, the programme should cover a documented risk assessment using a risk-based approach, customer due diligence and beneficial owner identification, ongoing transaction monitoring, sanctions and PEP screening, record-keeping for at least five years, suspicious transaction reporting, the appointment of a compliance officer, and staff training. Independent review or audit of the programme strengthens it. These controls turn legal obligations into a repeatable process a brokerage can evidence to the Ministry of Economy.
Legal Reference (UAE):
· Cabinet Resolution No. 134/2025 (Executive Regulations), Article 21 - requires internal AML policies, controls and procedures approved by senior management.
· Cabinet Resolution No. 134/2025 (Executive Regulations), Article 5 - requires a documented, risk-based assessment and mitigation of crime risks.
For more details, consult the full text of the Executive Regulations or seek guidance from your AML compliance officer.