Creating an AML policy is not just a formality, it's a regulatory requirement and a practical safeguard for your real estate business. Whether you're a broker, developer, or corporate service provider, having a clear and well-documented AML policy shows regulators that your firm is committed to preventing money laundering and financial crime.
This guide will walk you through the essential elements of an AML policy tailored for UAE real estate companies, including local requirements and best practices.
1. Why Every Real Estate Company in the UAE Needs an AML Policy?
Under UAE Federal Decree-Law No. (20) of 2018 and Cabinet Decision No. (10) of 2019, all Designated Non-Financial Businesses and Professions (DNFBPs), including real estate firms, must implement an internal AML policy.
An AML policy helps you:
- Define procedures for identifying and verifying clients (KYC)
- Establish clear steps for suspicious transaction monitoring and reporting
- Assign responsibilities (e.g., Compliance Officer)
- Maintain consistent documentation and training
2. What Should Be in an AML Policy?
A professionally drafted AML policy—aligned with UAE regulations—typically includes the following sections:
- Company Risk Profile: Summary of your business model, exposure to cash transactions, and customer demographics.
- KYC and CDD Procedures: Steps to verify client identity and perform due diligence.
- EDD Triggers and Protocols: How your firm handles high-risk clients (PEPs, offshore entities).
- Sanctions & PEP Screening: Regular screening practices and handling of potential matches.
- Suspicious Activity Monitoring: A list of red flags and how they're reviewed and escalated internally.
- STR/SAR Reporting Process: How reports are submitted via goAML.
- Record-Keeping and Privacy: What information is stored and for how long.
- Staff Training & Internal Audits: Frequency of AML training and how compliance is evaluated.
- Regulatory References: Links to relevant UAE AML laws, FATF standards, and Ministry of Economy expectations.
Including these sections not only ensures compliance but also demonstrates that your firm takes its AML obligations seriously.
3. UAE-Specific AML Requirements to Consider
Real estate companies in the UAE should ensure that their AML policy aligns with:
- goAML system expectations for STR/SAR submission
- Ministry of Economy requirements for DNFBPs
- Risk-based approach as per FATF recommendations
- Naming an official Compliance Officer in the policy
- Clearly outlining reporting timelines and procedures
4. Maintaining and Updating Your AML Policy
A good AML policy is a living document. You should:
- Review and update at least once per year, or sooner if regulations change
- Involve senior management in approval
- Audit your own compliance periodically to ensure consistency
5. How InfoAML Helps You Enforce Your AML Policy
Writing the policy is one thing—executing it consistently is another. InfoAML is designed to help you:
- Track client KYC and EDD data securely
- Monitor risk levels and trigger alerts
- Generate audit-ready reports
- Submit SARs/STRs through structured workflows
Conclusion: Your AML policy is more than a document—it's your first line of defense. When drafted carefully and aligned with UAE regulations, it protects your business, reputation, and clients.
Need a customized AML policy aligned with UAE law?
We offer professionally drafted AML compliance policies for real estate firms and DNFBPs—tailored to your business.
→ Schedule a free consultation or ask about our AML Policy Drafting Service