RERA + Legal✓ Updated Jan 2026

AML Compliance for UAE Real Estate Brokers in 2026

New AML rules require source-of-funds verification. Walk through the goAML system and red flags to watch for.

·7 min read·By AgentsAI Editorial
New AML rules in 2026 require every UAE real estate broker to verify source of funds before accepting any property transaction above AED 100,000, with full records kept for at least seven years.

Who Must Comply and What Has Changed

Any licensed broker operating in Dubai, Abu Dhabi, Sharjah, Ajman or Ras Al Khaimah falls under the 2026 updates to Cabinet Decision No. 10 of 2019. This includes agents at Allsopp & Allsopp, Betterhomes, fäm, haus & haus, Driven Properties and independent RERA brokers. The threshold for mandatory due diligence dropped from AED 500,000 to AED 100,000, and failure to file a Suspicious Activity Report (SAR) can now trigger fines of up to AED 500,000 plus possible licence suspension by RERA or the Dubai Land Department (DLD).

Step-by-Step goAML Registration and Filing

  1. Register your brokerage on the goAML portal at goaml.gov.ae using your RERA trade licence number and the authorised signatory’s Emirates ID.
  2. Complete the AML/CFT questionnaire within 10 working days of registration; upload your company’s AML policy, client acceptance form and staff training records.
  3. For every qualifying transaction, create a new “Property Transaction” case in goAML and attach the source-of-funds documents: bank statements for the last six months, sale agreement, and proof of buyer’s income (salary certificate, audited accounts or inheritance documents).
  4. Submit the case within 48 hours of receiving cleared funds; retain the goAML reference number in your internal CRM for audit.
  5. If the system flags the transaction, file a Suspicious Activity Report immediately and freeze the deal until clearance from the Financial Intelligence Unit (FIU).

Common Red Flags in UAE Real Estate

  • Buyer insists on paying via multiple third-party accounts or cryptocurrency wallets not registered with VARA.
  • Funds originate from jurisdictions on the FATF grey list such as Nigeria or Myanmar without clear commercial justification.
  • Purchase price is 20–30 % above comparable sales in the same building (e.g., AED 2.8 million for a 1,200 sqft 2-bed in Dubai Marina when recent comps sit at AED 2.1 million).
  • Client requests rapid off-plan transfers using a power of attorney from a non-family member within 30 days of reservation.
  • Repeated ownership changes in JLT or JVC towers within six months, each time funded by new corporate entities with no trading history.

Practical Checks for Every Deal

Before issuing the Memorandum of Understanding, run the buyer’s name and passport number through the goAML watch-list and request a six-month bank statement stamped by the issuing bank. For corporate buyers, obtain the ultimate beneficial owner (UBO) declaration and verify the company’s trade licence via the Ministry of Economy portal. Record the service-charge amount for the unit (typically AED 18–25 per sqft in Dubai Marina, AED 12–15 in Arabian Ranches) and confirm it matches the DLD Ejari contract. Store all documents in a password-protected folder named with the goAML case reference for quick retrieval during RERA audits.

Record-Keeping and Staff Training

Keep digital copies of every source-of-funds file for seven years from the date of the transaction. Schedule quarterly internal training for all negotiators; document attendance and test scores. Brokers using Property Finder, Bayut or Dubizzle must add a mandatory “AML Status” field in their CRM that cannot be bypassed before listing goes live.

How long do I need to keep AML records?

Seven years from the transaction date, stored securely and accessible for RERA or FIU inspection.

Does goAML apply to off-plan sales?

Yes. Any payment above AED 100,000, including 10 % reservation deposits on projects in MBR City or Saadiyat Island, must be verified.

What happens if a red flag is ignored?

The brokerage risks fines up to AED 500,000, licence suspension, and personal liability for the responsible broker under updated 2026 enforcement rules.

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