Anti-Money Laundry
Written by Artyom Meltonyan
Updated at September 1st, 2025
Table of Contents
DHRE AML / KYC PROCEDURE FOR REAL ESTATE AGENTS
Internal Training Guide – July 2025
Audience: Sales & leasing agents, brokers, admins, and all frontline DHRE staff (non‑compliance).
Legal basis:Federal Decree‑Law No. 20 of 2018, Cabinet Decision No. 10 of 2019, and all subsequent UAE AML/CFT guidance for the real‑estate sector.
Golden Rule:ASK → VERIFY → ESCALATE.
You never “approve” a deal – Compliance does.
1 · MANDATORY FIVE‑STEP WORKFLOW
Follow these steps in sequence for every deal – buy, sell, lease, or rent.
STEP 1 — COLLECT KYC / KYB PACKAGE
- Individuals: Passport + Emirates ID, mobile, email, nationality/residence, purpose of purchase.
- Corporates: Trade licence, Memorandum & Articles, Ultimate Beneficial Owner (UBO) IDs + contact details.
- Record the declared source of funds (salary, business profits, investment exit, inheritance, etc.).
- Check that documents are genuine and in date; copy them – never keep originals overnight.
STEP 2 — PASS THE FILE TO COMPLIANCE (≤ 24 HRS)
- Upload scans to CRM and flag deal status “Pending Compliance”.
- The documents and details will be in theKYC and KYB forms
- Do NOT accept any money (deposit, booking fee, token) until written clearance is received.
STEP 3 — COMPLIANCE OFFICER SCANS & SCREENS
- Screens client & UBO names against: UN / OFAC sanctions, UAE Central Bank lists, World‑Check PEP database.
- Checks nationality versus sanctioned/high‑risk country list (see § 3).
- Rates the risk: Low · Medium · High.
- If a match or serious red flag appears → Enhanced Due Diligence (EDD) is opened.
STEP 4 — COMPLIANCE ISSUES “NEXT‑STEP” INSTRUCTIONS
- Low risk: Agent may collect funds & sign contracts.
- Medium/High risk: Extra documents/explanations required. Agent must help gather but NEVER coach the client.
- EDD or match: Compliance files Suspicious Transaction Report (STR) with the FIU; deal remains on hold until formal clearance.
STEP 5 — ONGOING MONITORING UNTIL CLOSING
- If anything changes (cash ≥ AED 55 k, crypto, third‑party payer, sudden urgency, etc.) → pause & re‑escalate.
- Keep all emails, WhatsApps, call notes in CRM.
- At transfer/registration, re‑verify the person actually paying and the payment route.
2 · RED‑FLAG TRIGGERS (INSTANT ESCALATION)
| # | Situation | Immediate Action |
| 1 | Cash payment ≥ AED 55 000 (single or linked) | Copy ID, pause deal, call Compliance |
| 2 | Crypto funding (any amount) | Explain it must pass through a licensed UAE VASP, pause, escalate |
| 3 | Payment from third‑party account | Identify & KYC the payer or escalate |
| 4 | Client is a Politically Exposed Person (PEP) or senior official | Gather info, no promises, escalate |
| 5 | Client from sanctioned/high‑risk country | Stop interaction; hand to Compliance |
| 6 | Refusal to provide ID / hides UBO | End meeting, escalate |
| 7 | Multiple units / flip within 6 months, price far from market | Flag for EDD |
3 · SANCTIONED & HIGH‑RISK COUNTRY LIST (AUTO‑ESCALATE)
Iran –DPRK Syria – Myanmar – Sudan Russia* (if subject to international sanctions)
Crimea, Donetsk, Luhansk
-any state on the current FATF “High‑Risk Jurisdictions” list.
Always ask “Where is the money coming from?” even if the client holds a second passport.
4 · DO’S & DON’TS CHEAT‑SHEET
| ✅ DO | ❌ DON’T |
| Ask: “Where are these funds coming from?” | Accept “It’s private” as an answer |
| Store every document in the CRM | Keep IDs on your personal phone |
| Pause & escalate if unsure | Take any payment before clearance |
| Use the company sanctions‑screening tool | Tip‑off the client that you are filing a report |
5 · WHO TO CALL
| Need Help With… | Contact |
| Compliance queries / red flags | Compliance Officer: (Interim) [Name & ext.] |
| IT / Screening tool issues | DHRE IT Support |
| Extra AML training | HR / Compliance Training Lead |
ZERO‑TOLERANCE REMINDER
One overlooked red flag can cost up to AED 5 million in fines and the loss of our brokerage licence.
Ask → Verify → Escalate – every time.
