When can a UAE real estate broker accept payment in virtual assets?
Payment in virtual assets is permitted in UAE real estate transactions, but it triggers an automatic Real Estate Activity Report obligation regardless of value. Under the Ministry of Economy and Tourism Circular 5 of 2022, every freehold purchase or sale settled wholly or partly in virtual assets must be reported via the goAML portal. The same obligation applies where the funds were converted from a virtual asset into fiat shortly before the transaction, even if the broker only sees the fiat leg.
In practice the broker must obtain documentary evidence of the conversion, the originating wallet address, the exchange used, and the source of the underlying virtual asset. The exchange or virtual asset service provider must hold a UAE licence under the relevant federal or local regime, and the broker should confirm this before the transaction proceeds. Receiving funds from an unlicensed VASP is itself a suspicious indicator and a separate risk under the EOCN joint guidance, requiring an STR consideration in addition to the standard REAR.
Legal Reference (UAE):
- MOEC Circular No. 5/2022, Paragraphs 2 and 3 require a REAR for any freehold transaction paid in virtual assets or in fiat converted from virtual assets.
For more details, consult the full text of MOEC Circular 5 of 2022