Why are UAE real estate agents described as gatekeepers?
The Supplemental Guidance describes real estate agents and brokers as occupying a critical gatekeeper position, because their role gives them direct visibility over the flow of funds, the identities of the parties, the ownership structure, the purpose and structure of the transaction, and often the methods by which the transaction is financed or settled.
That visibility is exactly what a laundering scheme needs to keep hidden. An agent who sees a payment arriving from an account not in the buyer’s name, or a purchasing entity substituted late in the deal, is seeing something no other regulated party may see in one place.
The guidance draws the obvious conclusion. Agents must exercise professional judgement in identifying red flags, assessing whether transactions are consistent with the customer’s known profile, the stated purpose, and the broader economic context.
Legal Reference (source document):
· Supplemental Guidance for Real Estate Agents and Brokers, Ministry of Economy and Tourism, March 2026
· Cabinet Resolution No. 134 of 2025, Executive Regulations of Federal Decree-Law No. 10 of 2025
Scope note: as set out in the MoET Supplemental Guidance for Real Estate Agents and Brokers, March 2026.
Further reading: AML best practice for real estate agents
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