UAE Anti-Money Laundering Law: What Property Buyers Need
The UAE's anti-money laundering law is Federal Decree-Law No. 10 of 2025, in force since 14 October 2025. It replaced the 2018 law and reaches further into real estate, so if you are buying property in Dubai, your broker and your bank may now ask for more paperwork about where your money comes from than they did a year ago.
What is the UAE's anti-money laundering law?
Federal Decree-Law No. 10 of 2025, on anti-money laundering, combating the financing of terrorism and financing of proliferation, took effect on 14 October 2025 and repealed Federal Decree-Law No. 20 of 2018. Its executive regulations, Cabinet Resolution No. 134 of 2025, took effect on 14 December 2025 and replaced the previous executive regulations from 2019. Together they set out who must check customers, what records to keep and when to report a transaction.
Real estate brokers and agents are named directly in the regulations. Under Article 3 of Cabinet Resolution No. 134 of 2025, a broker or agent counts as a Designated Non-Financial Business or Profession whenever they conclude a purchase or sale on a customer's behalf, which puts them under the same due diligence duties as banks for that deal.
What documents do you need to buy property in Dubai under these rules?
The law does not create a new universal document list. It puts a duty on your broker and your bank to check and keep what you already give them. In practice, expect to provide:
- A valid passport, and an Emirates ID if you already hold a UAE residency visa.
- Proof of where your purchase funds came from, for example a previous sale deed, a salary certificate, business accounts or bank statements covering the deposit.
- For a company purchase, the trade licence, memorandum of association and a list of shareholders or beneficial owners.
- A power of attorney, legalised and translated, if someone else is signing on your behalf.
Our step by step buying guide covers the paperwork for each stage of a purchase; this article focuses on why the checks exist and what changed.
How do source of funds checks work for Dubai property?
Under Article 6 of Cabinet Resolution No. 134 of 2025, a broker or bank must verify your identity and, where one exists, the identity of the beneficial owner of the money, before or during the deal. Article 8 of the same regulations adds that they must keep checking the transaction against what they know about you, including, where necessary, the source of funds. That is the legal basis for a broker asking where your deposit came from, an ongoing duty that runs for as long as the relationship lasts.
A bank also has to run this check whenever it handles an occasional transaction of AED 55,000 or more, or a wire transfer of AED 3,500 or more, under Article 7 of the same regulations. A property purchase almost always crosses both figures, so the bank receiving your transfer will ask its own questions alongside your broker's.
What are the cash payment limits for property in Dubai?
There is no cap on how much cash you can pay for a property. What exists is a reporting rule: under a Ministry of Economy and Financial Intelligence Unit requirement in force since 1 July 2022, real estate agents, brokers and law firms have had to file a Real Estate Transaction Report to the Financial Intelligence Unit through its goAML platform whenever a single cash payment, or several linked cash payments, reaches AED 55,000. The same 2022 requirement applies if any part of the payment uses a virtual asset, or funds converted from one, whatever the amount.
The table below lines up the checks that apply to a typical Dubai purchase.
| Trigger | Threshold | Who must act | What happens |
|---|---|---|---|
| Cash payment, single or linked | AED 55,000 or more | Broker, agent or law firm | Files a Real Estate Transaction Report via goAML |
| Occasional bank transaction | AED 55,000 or more | Bank | Runs customer due diligence under Cabinet Resolution No. 134 of 2025 |
| Wire transfer | AED 3,500 or more | Bank | Runs customer due diligence under the same regulations |
| Virtual asset payment | Any amount | Broker, agent or law firm | Files a Real Estate Transaction Report regardless of value |
| Record keeping | Not amount based | Broker or bank | Keeps transaction records for at least 5 years |
How do payments to developers and escrow accounts work?
If you buy off plan, your payments do not go to the developer directly. Law No. 8 of 2007 requires every off-plan project to have its own escrow account, dedicated exclusively to the construction of that project, and no creditor of the developer can touch it. The developer draws from the account in stages, released as building work reaches agreed milestones.
Two further protections sit inside the same law. Under Article 14 of Law No. 8 of 2007, the escrow agent holds back 5% of the account's total value until a year after your unit is registered in your name. If a project stalls, Article 15 of the same law requires the escrow agent to act to protect buyers, either by completing the project or refunding what they paid in.
What must your broker do differently now?
Because brokers are named as a Designated Non-Financial Business or Profession, they carry the same four duties through every deal: verify who you are and who owns the money, watch the transaction, report it when the triggers above are met, and keep the file for five years.
None of this changes the price you pay or the steps in a purchase. When a RERA-registered agent asks more questions than you expected, they are meeting a legal duty. You can meet AKT's own RERA-registered agents before you start a file.
Why can't payment go to a seller's agent or power of attorney holder?
If you are buying a resale property rather than an off-plan unit, the Dubai Land Department has tightened how the seller gets paid. Since June 2025, reported by Gulf News and confirmed in a legal analysis of DLD Circular No. 29/R/2025, a cheque or manager's cheque for the sale has had to be issued in the seller's own name, the person on the title deed, rather than to a power of attorney holder. A cheque can still go to an agent, but only with a receipt stating plainly that the money was received on the seller's behalf.
For a buyer, the practical effect is that your payment instructions will name the title-deed holder directly, even when a power of attorney is managing the rest of the sale. If you are the one selling a property, our selling guide covers what else to prepare.
Exceptions to know
The escrow protections in Law No. 8 of 2007 cover off-plan projects only. A ready, already-registered unit on the secondary market is paid for under the sale contract rather than through a project escrow account, which is why the title-deed payment rule matters most for a resale.
The AED 55,000 and AED 3,500 figures in Article 7 of Cabinet Resolution No. 134 of 2025 apply to occasional transactions. A bank that already verified your identity when you opened your account does not repeat that full check on every transfer, though Article 8 still requires it to keep watching the transaction.
A company purchase adds a step beyond what an individual buyer faces. Under Article 6 of the same regulations, your broker or bank has to identify the beneficial owners behind the company as well as the company itself.
Frequently asked questions
Is cash still accepted for buying property in Dubai?
Yes. There is no legal cap on a cash payment for property. Once a single payment, or several linked cash payments, reach AED 55,000, the broker or law firm handling the deal must report it to the Financial Intelligence Unit through goAML.
Do I need a bank account in the UAE to buy property?
Not to buy. You can pay from an overseas account through a bank or licensed exchange house. A UAE bank account becomes relevant if you are the one selling later, since sale proceeds now have to reach the title-deed holder's own name.
Does the anti-money laundering law apply to off-plan purchases?
Yes, and it sits alongside the separate escrow rules in Law No. 8 of 2007. Your developer still cannot touch your off-plan payments outside the escrow account, and your broker still has to run the same customer checks as on a resale deal.
What happens if I pay with cryptocurrency?
A payment that uses a virtual asset, or funds converted from one, has to be reported to the Financial Intelligence Unit in the same way as a large cash payment, whatever the amount. Expect your broker to ask more questions about the source of those funds.
How long does my broker keep my documents?
At least five years from when the transaction or the business relationship ends, under Article 25 of Cabinet Resolution No. 134 of 2025. The same rule applies to banks.
How we checked this
Written by the AKT Real Estate research team (RERA ORN 15673, Business Bay, Dubai). Facts checked against the official sources below on 8 October 2026.
We read Cabinet Resolution No. 134 of 2025 and Law No. 8 of 2007 directly, on the UAE Ministry of Justice and Dubai Legislation sites, on 5 October 2026, and cross-checked the law's name, number and dates against legal updates from DLA Piper and Hadef & Partners, both October 2025. The AED 55,000 real estate cash-reporting rule was checked against a law firm's summary of the 2022 announcement and a government-linked news report of the same announcement. The title-deed payment rule was reported by Gulf News in June 2025 and set out in a legal analysis of DLD Circular No. 29/R/2025. We could not find that circular's full text on an official Dubai Land Department page, so we describe its payment mechanics as that legal analysis states them, without quoting the circular directly.
Sources
- Federal Decree-Law No. 10 of 2025 and its executive regulations: Cabinet Resolution No. 134 of 2025, UAE Ministry of Justice
- Escrow accounts for off-plan developments: Law No. 8 of 2007, Dubai Legislation
- Real estate cash reporting threshold and the goAML platform: Ministry of Economy and UAE Financial Intelligence Unit announcement, 2022, reported by Afridi & Angell and Sharjah Media.
- Dubai Land Department rule on sale proceeds reaching the title-deed holder's name: Gulf News, 17 June 2025.
AKT Real Estate is a RERA-registered brokerage in Business Bay, and our team runs these checks on every file. If you are ready to start, our guide to buying property in Dubai is the place to begin.
This article is general information, current on its publication date. Rules and fees change; check with the relevant authority or a licensed adviser before acting.