What is the role of the AML Compliance Officer in a UAE real estate brokerage?
Every UAE real estate brokerage that concludes property purchases or sales for customers must appoint an AML Compliance Officer at management level. The role must be independent, adequately resourced, and reported to senior management or the board. The Compliance Officer is responsible for the design, implementation and ongoing monitoring of the firm’s AML/CFT/CPF programme.
Day-to-day duties include conducting and updating the Enterprise-Wide Risk Assessment, maintaining policies, procedures and controls, overseeing customer due diligence and Enhanced Due Diligence files, reviewing and submitting suspicious transaction reports through the goAML portal, ensuring continuous sanctions screening and freezing actions where required, supervising the REAR filing process, organising AML training for all staff, and acting as the single point of contact with the Ministry of Economy and Tourism, the FIU and the Executive Office for Control and Non-Proliferation. The Compliance Officer must be sufficiently competent, free from conflicts, and able to refuse senior-management instructions that conflict with AML obligations.
Legal Reference (UAE):
- Cabinet Resolution No. 134 of 2025, Article 22 sets the appointment, independence and duties of the Compliance Officer; Article 21 covers the surrounding internal controls.
- Cabinet Resolution No. 71 of 2024, Items 24 and 25 fine Compliance Officer failures from AED 50,000 up to AED 500,000.
For more details, consult the full text of Cabinet Resolution 134 of 2025
Role of an AML Compliance Officer in a real estate brokerage