Anti-Money Laundering Notice
Version 0.1 · Effective June 2, 2026
Dubai's obligations and user responsibilities under UAE anti-money laundering and counter-terrorist financing law, with focus on real estate as a designated non-financial business.
1. Why This Notice Exists
The United Arab Emirates has established a comprehensive legal framework to combat money laundering, terrorist financing, and the financing of illegal organisations. The primary legislation is UAE Federal Decree-Law No. 20 of 2018 on Anti-Money Laundering and Combating the Financing of Terrorism and Illegal Organisations ("AML Law"), as amended, together with its implementing Cabinet Decisions and the regulations issued by the UAE Central Bank and the Ministry of Economy.
Real estate is classified as a Designated Non-Financial Business and Profession ("DNFBP") under the AML Law and Cabinet Decision No. 10 of 2019 concerning the Implementing Regulation. As a marketplace that facilitates real estate transactions — including property sales, rentals, and off-plan purchases — Dubai Marketplace FZ-LLC ("Dubai", "we", "us", "our") is subject to DNFBP obligations under the AML Law, and brokers and agencies operating through the Service have their own independent regulatory obligations.
This notice explains our AML/CFT framework, the obligations that apply to brokers and agencies using the Service, and how we expect all platform participants to support a clean, transparent marketplace.
2. Our Obligations as a DNFBP Platform
As a DNFBP, Dubai is required by UAE law to:
2.1 Customer Due Diligence (CDD)
We are required to verify the identity of brokers, agencies, and, in certain circumstances, parties to transactions conducted through the platform. CDD measures include:
- Collecting and verifying the identity of brokers and agencies at onboarding (name, trade licence, RERA registration, Emirates ID or passport of beneficial owners and authorised signatories);
- Identifying the beneficial owner of any legal entity that registers for a broker or agency account;
- Applying Enhanced Due Diligence ("EDD") to accounts presenting higher risk, including Politically Exposed Persons ("PEPs"), accounts with transaction patterns inconsistent with their stated business, and accounts in higher-risk jurisdictions;
- Keeping CDD records updated and repeating verification when circumstances change materially.
2.2 Ongoing Monitoring
We monitor transactions conducted on the platform for patterns that may indicate money laundering or terrorist financing. Monitoring includes reviewing:
- Unusual or unexplained changes in transaction volume or value;
- Transactions involving parties from high-risk jurisdictions identified by the Financial Action Task Force (FATF);
- Patterns inconsistent with a user's stated business activity;
- Rapid resale of recently acquired property at a loss or without apparent commercial explanation.
2.3 Reporting Suspicious Transactions
Where we identify a transaction or activity that gives us reasonable grounds to suspect money laundering or terrorist financing, we are obliged to file a Suspicious Transaction Report ("STR") or Suspicious Activity Report ("SAR") with the UAE Financial Intelligence Unit ("FIU") via the goAML reporting platform. We may take this step without informing the affected user (see Section 6 on tipping-off).
2.4 Record-Keeping
We maintain records of CDD information and transaction data for a minimum of 5 years following the end of a business relationship or a one-off transaction, in accordance with Article 16 of the AML Law.
3. Broker and Agency Obligations
Brokers and real estate agencies licensed under RERA who use Dubai to conduct or facilitate real estate transactions are themselves subject to the AML Law as DNFBPs. By using the Service to conduct real estate business, you represent and warrant that you are independently compliant with all applicable AML/CFT obligations. Your use of Dubai does not substitute for or satisfy your independent legal obligations.
3.1 Maintain Client Identity Records
You must collect and retain identity documentation for your clients — both buyers and sellers — to a standard meeting the CDD requirements of the AML Law. For individual clients, this means a valid Emirates ID (for UAE residents) or passport (for non-residents). For corporate clients, this means trade licence, memorandum of association, and Emirates IDs or passports of authorised signatories and beneficial owners.
Records must be retained for 5 years from the date of the transaction or the end of the client relationship, whichever is later.
3.2 Identify Beneficial Owners
Where a client is a legal entity (company, foundation, trust, or similar), you must take reasonable steps to identify the ultimate beneficial owner — the individual(s) who directly or indirectly own or control 25% or more of the entity, or who otherwise exercise effective control. Do not proceed with a transaction if you cannot identify the beneficial owner after making reasonable enquiries.
3.3 Decline Suspicious Transactions
If a proposed transaction raises AML/CFT concerns — including any of the red flags described in Section 5 — you must decline to proceed, or suspend the transaction pending further investigation, before submitting your own STR/SAR to the FIU via goAML.
3.4 Report Suspicious Transactions to Your Compliance Officer
Before filing externally, your agency's internal AML compliance officer should be notified of suspected suspicious activity so that the firm's internal investigation process can be followed. Only after internal escalation should the STR/SAR be filed with the FIU (or, if timing is critical, simultaneously).
3.5 Do Not Tip Off
It is a criminal offence under UAE law to disclose to a client, or any other person, that an STR/SAR has been or may be filed in connection with their activity. See Section 6.
4. Cash Transaction Reporting Threshold
Pursuant to Cabinet Decision No. 16 of 2021 on the Executive Regulations of Federal Decree-Law No. 20 of 2018, real estate transactions involving cash payments of AED 55,000 or more are subject to specific reporting obligations. Brokers and developers involved in such transactions must submit a Designated Non-Financial Businesses and Professions Report to the relevant supervisory authority.
Dubai does not directly handle cash. However, brokers and agencies who become aware of cash payments at or above this threshold in connection with a transaction facilitated through our platform must comply with their own reporting obligations independently of their use of Dubai.
If you have any doubt about whether a transaction triggers this threshold or any other reporting obligation, you should obtain independent legal advice.
5. Red Flags
The following circumstances should heighten your AML/CFT vigilance. They do not automatically indicate criminality, but they warrant additional scrutiny, enhanced due diligence, and, where suspicion cannot be resolved, a suspicious transaction report:
- Rapid resale: A client seeks to purchase and then quickly resell a property at a loss or at a price that does not reflect market conditions, without a credible commercial explanation.
- Structuring: A client or counterparty appears to be breaking a single transaction into multiple smaller transactions to avoid a reporting threshold or other control.
- Reluctance to provide identity documents: A client is unwilling to provide standard identity documentation, or provides documents that appear altered or falsified.
- Third-party payments without explanation: Payment for a property is made by a person other than the buyer, without a clear and credible explanation for the arrangement.
- Excessive use of cash: A client wishes to pay in cash an amount that appears disproportionate to their apparent means or the nature of the transaction.
- Anonymity-seeking: A client refuses to identify who the ultimate beneficial owner of a transaction is, or uses complex corporate structures that serve no apparent commercial purpose other than to obscure ownership.
- Geographic inconsistency: Funds are routed through or from high-risk jurisdictions identified by the FATF's grey or black lists, without a satisfactory explanation.
- Price inconsistency: The agreed price is significantly above or below market value for the property, particularly where the deviation is hard to explain based on the property's characteristics.
This list is illustrative, not exhaustive. Good professional judgment and knowledge of your client remain the most important tools in AML/CFT compliance.
6. Confidentiality and Tipping-Off
UAE AML Law expressly prohibits "tipping off" — that is, disclosing to a client or any third party that a suspicious transaction report has been or may be filed in connection with them, or disclosing any information that could prejudice an investigation into their activities. Tipping off is a criminal offence.
If you receive enquiries from a client about why you are requesting additional documentation, or why a transaction is being delayed, you should not disclose that AML concerns are the reason. You may state that enhanced verification is a standard compliance requirement.
Similarly, if you become aware that Dubai has placed additional verification requirements on an account in connection with an AML review, you must not disclose this to the affected user.
7. Whom to Contact
Dubai AML and compliance queries:
- Email: aml@example.com
- AML Compliance Officer: The designated AML Compliance Officer for Dubai Marketplace FZ-LLC will be named here once appointed. In the interim, all correspondence should be directed to the email above.
External regulatory contacts:
- UAE Financial Intelligence Unit (FIU): Suspicious transaction reports may be filed via the goAML portal at www.uaefiu.gov.ae.
- RERA Compliance: Brokers with RERA-specific AML compliance questions should contact RERA directly.
This notice does not constitute legal advice. Brokers and agencies are strongly encouraged to seek independent legal advice on their specific AML/CFT obligations from a qualified UAE law practitioner.