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AML obligations for real estate brokers and gold dealers in the UAE
Two of the most closely supervised sectors in the UAE. Here is what is actually required of them, and where the common mistakes sit.
Real estate brokerage and dealing in precious metals and stones receive particular attention from UAE regulators, because of the sums involved and how readily they can be used to move illicit funds. That means their AML obligations are not a formality.
What is required of the business?
- Appointing a qualified compliance officer
- Completing registration on the required platforms
- Preparing a documented entity risk assessment
- Writing policies and procedures that can actually be applied
- Applying due diligence to customers and beneficial owners
- Training staff periodically and documenting it
- Retaining records for the prescribed period
Where do the common mistakes sit?
The first is policies copied from a generic template that looks nothing like the activity — present on paper but impossible to apply. The second is screening a customer once at onboarding and never updating the file again.
The third and most expensive is missing documentation: a step that genuinely happened but cannot be evidenced. In a regulatory review, what cannot be evidenced is treated as though it never occurred.
What is specific to gold and jewellery
This sector handles higher cash amounts and high-value, easily transportable goods, which raises the risk level and calls for stronger due diligence — particularly on large cash transactions and walk-in customers.
What is specific to real estate
Property transactions are large, infrequent and involve several parties, so the risk concentrates on verifying source of funds and identifying the real beneficial owner behind purchasing entities.
Where do you start?
Start with your entity risk assessment — it is the foundation everything else rests on, and it determines the intensity of due diligence, the degree of monitoring and training priorities.
