In February 2024, the Financial Action Task Force (FATF) removed the UAE from its grey list, recognizing the country’s progress in tackling money laundering and terrorist financing. Two years on, the bar has only risen. In 2026, the UAE will undergo its next mutual evaluation by the FATF and its regional body, MENAFATF, with an on-site visit by assessors scheduled for June.
With hundreds of billions of dirhams in transactions each year and buyers arriving from all over the world, real estate remains one of the sectors regulators watch most closely. For developers, brokers, investors and property managers, strong anti-money laundering (AML) compliance is essential to uphold market integrity and trust in Dubai’s property sector.
A New Federal AML Law
The biggest change since this article was first published is a new legal foundation. Federal Decree-Law No. 10 of 2025 on Anti-Money Laundering, Combating the Financing of Terrorism and Proliferation Financing took effect on 14 October 2025. It repealed Federal Decree-Law No. 20 of 2018, the UAE’s main AML law for seven years.
Cabinet Resolution No. 134 of 2025 supports the new law as its implementing regulation. Together they widen the scope of the regime and toughen penalties. Real estate, high-value goods, corporate services, and virtual assets are now fully under regulatory monitoring. The law also adds proliferation financing as an offense, extends coverage to virtual asset service providers, and brings tax evasion within the crimes that can give rise to money laundering.
What the Rules Require in Real Estate
Real estate brokers and agents are classed as Designated Non-Financial Businesses and Professions (DNFBPs) and are supervised for AML purposes by the Ministry of Economy and Tourism. In practice, this means several core obligations.
Customer due diligence. Brokers and agents must verify clients’ identities, understand the purpose of the transaction, and identify the ultimate beneficial owner behind any company or trust buying or selling.
Enhanced due diligence for higher-risk clients. Additional checks apply where risk is higher, such as complex ownership structures, politically exposed persons, or clients linked to higher-risk jurisdictions.
Source of funds. Buyers must be able to show where their money came from, whether it is held in a bank account, in cash, or in virtual assets.
Real Estate Activity Reports. Under Ministry of Economy Circular No. 5 of 2022, brokers and agents must file a Real Estate Activity Report through the Financial Intelligence Unit’s goAML platform for any freehold purchase or sale involving cash of AED 55,000 or more, whether paid in one payment or several. The same report is required when any part of the payment is made in virtual assets, or with funds converted from virtual assets.
Suspicious transaction reporting. Any transaction or activity that raises suspicion must be reported to the Financial Intelligence Unit through goAML, regardless of its value.
Enforcement Is Real and Ongoing
The Ministry of Economy and Tourism inspects DNFBPs through both desk reviews and field visits. In the first half of 2025 alone, its inspections uncovered 1,063 violations and led to fines of more than AED 42 million. Real estate brokerages accounted for 495 of those violations, with penalties totaling around AED 18.5 million.
To address enforcement concerns, explain how the Ministry of Economy and Tourism monitors compliance through inspections and audits, and specify penalties such as fines exceeding AED 18.5 million, emphasizing the importance of proactive compliance to avoid reputational and operational risks.
Enforcement also extends beyond regulated businesses. During 2025, UAE authorities confiscated assets valued at AED 5.4 billion as part of the national effort against financial crime.
Virtual Assets and the Rise of Tokenization
Crypto and other virtual assets are part of Dubai’s property market, and the rules around them are among the strictest. Any freehold transaction paid wholly or partly in virtual assets triggers a Real Estate Activity Report, and buyers face the same source-of-funds expectations as those paying in dirhams. The new federal AML law also brings virtual asset service providers fully into scope. In Dubai, they must be licensed by the Virtual Assets Regulatory Authority (VARA).
At the same time, Dubai is building regulated routes for digital property investment. The Dubai Land Department has been working with VARA on a real estate tokenization initiative that links tokenized ownership to the official property register. For investors, the message is clear. Digital channels are welcome in Dubai, but only within regulated, traceable frameworks.
What This Means for the Market in 2026
For brokers and agents. AML compliance is a licensing reality, not an optional extra. Inspections check registration on goAML, documented due diligence, and timely reporting.
For developers. Developers selling directly, accepting virtual assets, or working through third-party agents need to understand where AML obligations sit in their sales process, and to choose partners who meet them. Institutional investors and lenders increasingly assess compliance as part of their own due diligence.
For investors and buyers. Expect to be asked for identification, proof of the source of funds and, for companies, details of beneficial ownership. Complete documentation speeds transactions, not slows them.
For property owners and managers. Clean ownership records and clear documentation support smoother resales, refinancing and handovers later in an asset’s life.
Staying Ahead in 2026
Review policies against the new law. Update AML manuals to reflect Federal Decree-Law No. 10 of 2025 and Cabinet Resolution No. 134 of 2025 to ensure your team is prepared and compliant in 2026.
Invest in systems. Digital identity checks, beneficial ownership verification, sanctions screening, and transaction monitoring reduce both risk and manual error.
Train teams regularly. Sales, leasing and finance teams should know the red flags, the AED 55,000 cash threshold, the virtual asset reporting trigger and how to escalate a concern.
Vet partners. Work only with licensed brokers and agents, and with VARA-licensed providers for any virtual asset payments.
Keep ownership structures transparent. Unnecessarily complex structures attract scrutiny and slow down transactions.
Trust Is Dubai’s Real Competitive Advantage
Dubai’s property market offers strong fundamentals and global reach, and the UAE has made clear that it intends to protect that position through robust financial integrity. With a new federal AML law in force and a FATF evaluation underway in 2026, compliance is now a mark of credibility. Businesses that treat it as part of their value, rather than a burden, will be best placed to attract quality investment for years to come.
Frequently Asked Questions
What is the main AML law in the UAE in 2026?
Federal Decree-Law No. 10 of 2025, which came into force on 14 October 2025 and replaced Federal Decree-Law No. 20 of 2018. Cabinet Resolution No. 134 of 2025 implements it.
Who supervises AML compliance for real estate brokers?
The Ministry of Economy and Tourism supervises real estate brokers and agents as Designated Non-Financial Businesses and Professions.
When must a property transaction be reported?
A Real Estate Activity Report must be filed through goAML when a freehold purchase or sale involves cash of AED 55,000 or more, in one or several payments, or when any part of the payment is made in virtual assets. Suspicious transactions must be reported regardless of value.
Can I buy property in Dubai with cryptocurrency?
Payments involving virtual assets are permitted through regulated channels. Still, they trigger mandatory reporting, and buyers must document the source of the assets just as they would for any other funds.
