Real estate and precious metals have something important in common: significant value can move through a single transaction.
That makes these sectors commercially attractive, but it can also expose them to money laundering and other financial crime risks.
This is why real estate brokers and agents, and dealers in precious metals and stones, fall within the scope of the AML/CFT framework as Designated Non-Financial Businesses and Professions (DNFBPs) under the UAE law. Their compliance obligations are not simply administrative requirements attached to doing business. They are designed to help businesses understand who they are dealing with, where the risk lies and when a transaction deserves closer attention.
How Are They Captured Under the UAE AML Law?
Both sectors are expressly named as DNFBPs under Article 3 of Cabinet Resolution No. 134 of 2025, the Executive Regulations to Federal Decree-Law No. 10 of 2025. Real estate brokers and agents are captured when they conclude a transaction for a customer relating to the purchase or sale of real estate; dealers in precious metals and stones are captured once they carry out a single, or linked, cash transaction at or above AED 55,000. Being named as a DNFBP is what brings a business into the AML/CFT regime in the first place and everything else in this article follows from that starting point.
Supervision sits with the Ministry of Economy and Tourism (MoET), and registration on the UAE’s goAML portal is mandatory once a business falls within scope. From there, the obligations largely mirror those that apply to financial institutions: customer due diligence, ongoing monitoring, suspicious activity reporting, and as set out below, sector-specific filings and record-keeping requirements that apply on top of the general framework.
In real estate, who is really behind the transaction?
A property transaction may appear straightforward until a company, trust, nominee, third party or complex ownership structure sits behind the buyer or seller.
Knowing the name on the transaction is not always enough. Businesses need appropriate processes to identify and understand their customers and beneficial owners, assess the risks associated with the relationship and recognise circumstances that may warrant enhanced scrutiny.
Unusual ownership structures, unexplained third-party involvement or transactions that do not appear consistent with what is known about the customer can all raise questions that should not simply be overlooked.
Real Estate: Filings, Records and Monitoring at a Glance
In brief, real estate brokers and agents should be able to demonstrate:
- Real Estate Activity Report (REAR): filed with the UAE Financial Intelligence Unit via goAML where a transaction involves a cash payment of AED 55,000 or more (single or linked payments), or any element of virtual assets.
- Suspicious Transaction Reports (STRs): filed as soon as reasonable suspicion arises, independently of the REAR threshold.
- Record-keeping: customer, beneficial ownership and transaction records to be retained for a minimum of five years.
- Ongoing monitoring: transactions and customer relationships reviewed on a risk basis, not only at the point of sale.
For precious metals and stones, the risks can look different
Precious metals and stones combine high value, portability and ease of transfer, creating a different financial crime risk profile.
The challenge is therefore not simply completing customer due diligence. Businesses also need to understand the nature and purpose of relevant transactions, identify unusual activity, maintain appropriate records and apply enhanced measures where the circumstances and applicable requirements call for them.
Precious Metals and Stones: Filings, Records and Monitoring at a Glance
In brief, dealers in precious metals and stones should be able to demonstrate:
- DPMS Report (DPMSR): filed via goAML within two weeks of any single, or linked, cash transaction at or above AED 55,000, including cash-settled unfixed gold transactions.
- Suspicious Transaction Reports (STRs): a separate obligation to the DPMSR, triggered by suspicion rather than value.
- Record-keeping: DPMSR submissions, supporting documents and underlying transaction records retained for a minimum of five years.
- Ongoing monitoring: particular attention to cash-intensive patterns, structuring below the reporting threshold, and cross-border movement of stock.
Compliance has to work where the transaction happens
For both sectors, an AML/CFT framework is only effective when the people dealing with customers and transactions understand how to apply it.
AML compliance isn’t simply about completing a checklist. It is about recognising risk before a transaction becomes a problem.
For businesses operating in sectors where high-value transactions are part of everyday activity, getting those decisions right matters and being able to show the filings, records and monitoring behind that decision matters just as much.
Speak to our Compliance Team to explore how the right AML/CFT framework and ongoing compliance support can help your business identify, manage and mitigate financial crime risk.
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