Real estate is one of the most prominent and rapidly growing sectors in the UAE economy. However, its high-value transactions and international clientele make it a prime target for money laundering and illicit financing. To protect the sector and comply with global standards, the UAE has imposed stringent AML (Anti-Money Laundering) regulations, requiring real estate agents and brokerages to screen both buyers and sellers for AML risks.

In 2025, screening is no longer just best practice—it is a regulatory necessity backed by the Ministry of Economy, UAE FIU, and Cabinet Decision No. 10 of 2019.

The AML Risk in Real Estate Transactions

Criminals may use real estate to:

  • Convert illicit cash into valuable assets
  • Conceal ownership through third parties or shell companies
  • Launder money across borders through high-value deals
  • Use virtual assets for property payments to avoid traceability

To counteract these threats, real estate professionals in the UAE are legally required to perform Customer Due Diligence (CDD) and ongoing screening of all clients—whether buyers or sellers.

Legal Basis for Screening Buyers and Sellers

Under UAE AML regulations, real estate agents must:

  • Identify and verify the identity of clients before any transaction
  • Understand the purpose and source of funds used in the transaction
  • Screen clients against global sanctions lists, PEP databases, and adverse media
  • Report suspicious activity via the goAML portal, including REAR (Real Estate Activity Report) filings when applicable

Failure to conduct proper screening may result in regulatory fines, license suspension, or criminal liability.

Key Screening Requirements for Real Estate Agents
1. Sanctions List Screening

Agents must check all parties involved in a transaction against:

  • UN Security Council Sanctions List
  • OFAC (U.S. Treasury)
  • EU Sanctions
  • UAE’s National Terrorist List

 2. Politically Exposed Persons (PEP) Screening

PEPs and their close associates are high-risk clients due to their access to public funds. These individuals require Enhanced Due Diligence (EDD) and additional documentation.

 3. Adverse Media Checks

Screening for news articles or public information that may reveal:

  • Past involvement in financial crimes
  • Legal disputes or allegations
  • Connections to high-risk entities
Why Both Buyers and Sellers Must Be Screened

Some firms mistakenly screen only buyers, but both parties pose AML risks:

  • Buyers may use illicit funds or third-party financing
  • Sellers may be involved in criminal enterprises offloading assets
  • Shell companies or proxy buyers may be used to obscure true ownership

Screening both sides ensures full transparency and compliance.

How AML Software Helps Real Estate Firms Screen Effectively

Manual screening is inefficient and error-prone. An AML software solution like WinGuardAML enables real estate agents to:

  • Automatically screen buyers and sellers in real time
  • Integrate with global and UAE-specific watchlists
  • Flag high-risk clients for review
  • Maintain a digital audit trail for compliance audits
  • Assist in filing REAR reports to the UAE FIU

Conclusion

Screening buyers and sellers is a vital first step in any real estate transaction. With increasing regulatory enforcement in 2025, UAE real estate agents must prioritize AML compliance through structured due diligence and risk-based screening.

By adopting automated screening tools, real estate firms can confidently fulfill their regulatory obligations while safeguarding their reputation and avoiding penalties.

WinGuardAML provides the features real estate professionals need to screen, report, and stay compliant—efficiently and securely.