Real estate in the UAE is classified as a high-risk sector for money laundering — and this is not a guess. It’s a conclusion drawn directly from the UAE’s most recent National Risk Assessment (NRA).
For CEOs and compliance officers in the real estate sector, the implications are serious. Whether you’re a broker, developer, or property services firm, your business is on the frontline of AML enforcement.
This blog breaks down the top ML threats facing UAE real estate, drawn from the NRA, and what your leadership and compliance teams must do in 2025 to mitigate risk.
Why Real Estate Is a Target for Money Laundering
The NRA identifies real estate as a key vehicle for laundering due to its:
- High-value nature
- Capacity to store wealth
- Potential to obscure beneficial ownership
- Connection to cross-border and cash-based transactions
It’s not just about large villas and luxury towers. Even modest units can become part of laundering schemes when due diligence is weak.
Top Money Laundering Threats in UAE Real Estate (According to the NRA)
Download the full UAE National Risk Assessment (NRA) Report
Here are the most significant risks flagged by the NRA:
1. Obscured Beneficial Ownership
Criminals use legal persons (companies) or proxies to purchase property and conceal the real buyer.
"The use of legal persons and arrangements to obscure beneficial ownership continues to be a significant vulnerability in the real estate sector." — NRA Report, Section 3.1, Page 45 ✉ NRA Link: Medium-High misuse of legal entities in real estate deals.
2. Use of Third Parties and Nominees
Properties are registered under family members or associates to distance the true owner from scrutiny.
"Transactions involving third parties or nominees are commonly used to disguise the true ownership of real estate assets." — NRA Report, Section 3.2, Page 47
3. Cash and Unexplained Funds
Deals involving partial or full cash payments — especially where source of funds is vague or unverifiable — are high-risk.
"High-value cash transactions in real estate remain a concern, particularly when the source of funds cannot be readily verified." — NRA Report, Section 3.3, Page 50 ✉ Red Flag: Repeated attempts to avoid bank transfers or show inconsistent documentation.
4. Unusual Transaction Structures
"Complex transaction structures, including rapid resales and price manipulation, are indicative of potential money laundering activities." — NRA Report, Section 3.4, Page 52
- Payments made from unrelated third-party accounts
- Over- or under-valued property pricing
- Back-to-back sales within short timeframes
5. Use of Foreign Buyers with High-Risk Profiles
Foreign nationals from high-risk jurisdictions acquiring property via complex structures or offshore entities.
"The involvement of foreign buyers from high-risk jurisdictions, often using offshore entities, increases the vulnerability of the real estate sector." — NRA Report, Section 3.5, Page 55
6. Integration via Renovation or Rental
"Investment in property renovations and the generation of rental income are methods used to integrate illicit funds into the legitimate economy." — NRA Report, Section 3.6, Page 58 Property used to legitimize illicit funds through:
- Construction projects
- Long-term rental income
- Flipping ownership through related parties
What CEOs and Compliance Officers Must Do
This isn’t just a compliance issue — it’s a strategic business risk.
If your company is ever inspected by the Ministry of Economy or FIU:
- Weakness in verifying funds or ownership = Violation
- Lack of ongoing monitoring or risk scoring = Violation
- Poor internal reporting = Violation
Here’s what must happen at the leadership level:
- CEOs must treat AML as a license protection issue — not a delegated admin task.
- Compliance Officers must map internal controls directly to NRA threats.
- Both must ensure systems are in place to:
- Screen clients
- Document SoF and SoW
- Monitor high-risk profiles and transactions
How InfoAML Helps
InfoAML was built specifically to help UAE real estate firms comply with national AML laws and align with the NRA’s findings:
- Automated Risk Scoring based on geographic, client, and transaction risk
- Real-Time Sanctions & PEP Screening against UAE, UN, and custom lists
- Beneficial Ownership is tracked through internal notes and client-specific document folders — rather than a fixed field — offering flexibility and audit-ready evidence
- goAML-ready STR Reporting with built-in red flag prompts
Final Word
Real estate professionals must accept that they are operating in one of the most scrutinized sectors under UAE AML law. The NRA has spoken. The question is — are you listening?
InfoAML is here to help you stay ahead of the risk.
👉 Book a Demo or Learn more about InfoAML features