UAE Real Estate AML Starter Kit — What's Inside

Real estate is the most-inspected DNFBP sector in the UAE. In H1 2025 the Ministry of Economy and Tourism recorded 495 violations by real-estate brokerages — more than any other sector — with AED 18.5 million in fines. Since July 2022, brokers and agents must file a Real Estate Activity Report (REAR) on goAML whenever a freehold deal is paid wholly or partly in cash of AED 55,000 or more, in virtual assets, or in funds converted from a virtual asset — on top of due diligence on both buyer and seller, a written risk assessment, an appointed MLRO, screening, training and record-keeping. This kit is that framework, ready.

Document 01 · The Manual

AML/CFT Policy & Procedures Manual

The spine of the kit: the board-approved manual every other document supports. Your obligations under FDL 10/2025 and CR 134/2025 as a real-estate DNFBP; governance and the MLRO; the risk-based approach; due diligence on buyers and sellers; beneficial ownership; sanctions and PEP screening; transaction monitoring and the REAR; reporting, record-keeping, training and independent review. Pre-filled with your firm's details.

The rulebook

Policies & Procedures

8 documents

01 AML/CFT Policy & Procedures Manual The board-approved spine — every obligation, one document.
03 Sanctions & PEP Screening Policy UN + UAE lists, PEP handling, freeze-without-delay.
04 Record-Keeping & Data Retention Policy What you keep, in what form, for the five-year minimum.
05 Tipping-off Prevention & Confidentiality Policy The criminal line your staff must never cross.
06 Customer Onboarding & KYC Procedure Know both sides of the deal before it closes.
07 Enhanced Due Diligence Procedure PEPs, high-risk parties, source-of-funds — the deeper checks.
08 STR & goAML Filing Procedure Suspicion reports and the REAR, step by step.
09 Transaction Monitoring Procedure The REAR's three trigger cases, property red flags, structuring.

What you use day-to-day

Forms & Risk Tools

9 documents

10 Corporate KYC Questionnaire Companies, SPVs and their beneficial owners.
11 Individual KYC Questionnaire Buyers and sellers, identified properly.
12 UBO Declaration Form The real person behind the structure, on the record.
14 PEP Self-Declaration Form Politically exposed persons, declared at onboarding.
15 Source of Funds Declaration Where the purchase money actually comes from.
16 AML Risk Assessment Matrix Working Excel, live scoring — pre-weighted for a brokerage.
17 Sanctions Screening Log Every screen, recorded and defensible.
18 Annual Compliance Calendar Your year's obligations — including broker-registration renewal — anchored to your dates.
19 High-Risk Country Reference List The geographic-risk reference your risk scores lean on.

Sign-off and operations

Governance, Training & Quick Reference

9 documents

20 MLRO Appointment Letter The named, senior, accountable appointment — in writing.
21 MLRO Job Description What the role actually carries, including REAR filing.
22 MLRO Compliance Report Template The periodic report to senior management, ready to complete.
23 Independent AML Audit — ToR & Findings The third line of defence, scoped and documented.
24 Three-Lines-of-Defence Org Chart Your governance, on one slide.
25 Staff AML Awareness Training Deck 25 slides, ready to deliver — property red flags and the REAR included.
26 Red Flags for Real Estate Staff The one-page reference for the front office.
27 Inspection Readiness Checklist Self-check before the Ministry arrives.
28 Glossary & How to Use This Kit Plain-language terms and the order to work in.

What an inspection checks

Six things an inspector asks for. Six answers in the box.

i A written AML/CFT policy, adopted by management Answered by Doc 01.
ii A named, appointed MLRO Answered by Docs 20–22.
iii Customer due-diligence files Answered by Docs 06–07, 10–11.
iv A documented risk assessment Answered by Doc 16.
v REAR & STR filing procedures Answered by Docs 08–09.
vi Staff training records Answered by Docs 25–26.

Delivery · 48 Hours

All files in Word (.docx), Excel (.xlsx), PowerPoint (.pptx) and PDF Editable, not locked Yours forever

Keep it current — free, for 12 months.

Your kit comes with My Kit, a free account. If your MLRO, registered address or risk profile changes, update your profile and re-generate your kit — no re-purchase. And a built-in compliance calendar tracks your recurring obligations (risk-assessment review, MLRO report, training, broker/agent registration renewal, and REAR filing triggers) and reminds you before each one is due.

Sign in to My Kit →

Buyers offering to pay in crypto? In real estate that's not hypothetical — and a virtual-asset payment makes a deal reportable at any value. The Crypto Module (+€499) extends the kit: enhanced due diligence on crypto-funded purchases, source-of-virtual-assets checks, wallet-screening procedure, the licensed off-ramp, and the VASP boundary your staff must never cross — including the rules for taking your own commission in crypto.

Get the kit + Crypto Module — €1,198 ~~€1,398~~ →

Sign & Seal · Reg. Mark 2026

Inspection-ready in days. Customised to your brokerage.

Get the Real Estate Kit €699 ~~€899~~ →

Founding-firm pricing — first 10 firms, then €899.

14-day money-back guarantee · Stripe checkout · Instant download link · 12 months of free updates.

Federal Decree-Law 10 of 2025 Cabinet Resolution 134 of 2025 MoE Circular No. 05/2022 (REAR) goAML / UAE FIU