AML Fines in the UAE: Penalties and Inspections for Real Estate Brokers
AML fines in the UAE are set per violation: Federal Decree-Law No. 10 of 2025 allows a fine of AED 10,000 to AED 5,000,000 for each one, and Cabinet Resolution No. 71 of 2024 fixes a range for each of 41 specific violations. A single inspection that finds three gaps can produce three fines, and the Ministry can impose other sanctions, up to licence revocation, on top.
This guide covers AML penalties for real estate brokers on the mainland and in commercial free zones, who are supervised by the Ministry of Economy and Tourism (MoET): the sanctions and fines, the criminal offences, what inspections find, how to prepare and how to object to a fine. Brokers in ADGM and DIFC have their own regulators and are outside its scope.
How AML fines work in the UAE
Two documents decide what a broker pays.
Federal Decree-Law No. 10 of 2025 (FDL 10/2025), the UAE AML law, lists the administrative sanctions a supervisor can impose and sets the outer range of the fine: AED 10,000 to AED 5,000,000 for each violation (art. 17(1)(b)). What changed from the 2018 law is explained in our guide to Decree-Law 10 of 2025.
Cabinet Resolution No. 71 of 2024 (CR 71/2024) applies to DNFBPs supervised by the Ministry of Justice and the Ministry of Economy. Its annexed list names 41 violations and gives each one a minimum and a maximum fine. The Ministry can impose a fine from the list, another administrative sanction, or both (CR 71/2024, art. 3(1)).
Criminal penalties are separate. Only a court can impose them, and they apply to people as well as companies.
Administrative sanctions under article 17
When a supervisor finds a breach of the law, the Executive Regulations or a decision issued under them, art. 17(1) of FDL 10/2025 allows it to impose:
| Sanction | What it means for a brokerage |
|---|---|
| Warning | A formal written warning |
| Fine | AED 10,000 to AED 5,000,000 for each violation |
| Ban from the sector | You may not work in the sector where the violation happened, for a period the supervisor sets |
| Restricted powers | Limits on the powers of the board members, managers or owners proven responsible, including appointing a temporary supervisor |
| Suspension of managers | The directors or managers responsible are suspended for a period, or the supervisor asks for them to be replaced |
| Suspended activity | Your activity is suspended or restricted for a period the supervisor sets |
| Licence revocation | The trade licence is withdrawn |
Nothing in art. 17 requires the supervisor to start with a warning. Three more powers come with the list:
- Repeat violations. If the same violation recurs within one year of the previous fine for it, the supervisor can impose an increased fine (art. 17(3)). CR 71/2024 also allows the Ministry to double the fine when a violation is repeated (art. 5(2)).
- Publication. The supervisor can publish the sanctions it imposes in the media (art. 17(4)).
- Remediation reports. Alongside a sanction, the supervisor can order you to send periodic reports on how you are fixing the violation (art. 17(2)).
How much is the AML fine for each violation?
These are the lines of the CR 71/2024 list most relevant to a real estate broker. Amounts are in AED.
| No. | Violation (as described in the list) | Minimum | Maximum |
|---|---|---|---|
| 1 | No AML policies, procedures and internal controls approved by senior management | 100,000 | 200,000 |
| 5 | Not identifying, assessing, documenting and updating the business’s ML/TF risks | 50,000 | 500,000 |
| 7 | Not taking measures to mitigate the risks identified by the National Risk Assessment or your own assessment | 50,000 | 1,000,000 |
| 9 | Not carrying out customer due diligence before starting the relationship or an occasional transaction | 50,000 | 200,000 |
| 11 | Not verifying the identity of the customer and the beneficial owner from a reliable, independent source | 50,000 | 200,000 |
| 15 | Not applying enhanced due diligence where high risk is identified | 100,000 | 500,000 |
| 18 | No system to establish whether a customer or beneficial owner is a politically exposed person | 50,000 | 200,000 |
| 22 | Not promptly filing a suspicious transaction report with the FIU, or not giving the FIU the extra information it asks for | 100,000 | 500,000 |
| 23 | Not registering on the FIU’s electronic system (goAML) | 50,000 | 200,000 |
| 24 | Not appointing a Compliance Officer with the right competence and experience | 50,000 | 200,000 |
| 26 | Not keeping the required records, or not producing them promptly on request | 50,000 | 200,000 |
| 28 | Telling the customer or anyone else about a suspicious transaction report or an investigation | 100,000 | 500,000 |
| 33 | Not registering with the Executive Office (EOCN) to receive sanctions list notifications | 50,000 | 1,000,000 |
| 34 | Not screening customers and transactions against the sanctions lists | 50,000 | 1,000,000 |
| 35 | Not freezing funds promptly when a sanctions match appears | 500,000 | 1,000,000 |
The list has no line that names the Real Estate Activity Report (REAR). MoET’s March 2026 guidance for brokers says that failing to file REARs within the set parameters and timelines can expose a broker to regulatory action.
Because each violation is fined separately, the amounts add up quickly. Take an inspection that finds no documented risk assessment (line 5), no PEP checks (line 18) and customer files that can’t be produced (line 26). On the list’s minimums alone that is AED 150,000, and the combined maximum is AED 900,000.
Is Cabinet Resolution 71 of 2024 still in force?
Yes, as far as the official sources show. CR 71/2024 was issued on 8 July 2024 under the 2018 AML law and replaced Cabinet Resolution No. 16 of 2021. When FDL 10/2025 repealed the 2018 law, it kept the resolutions issued under it in force as long as they don’t conflict with the new law, until replacements are issued (art. 41(3)). Cabinet Resolution No. 134 of 2025, the new Executive Regulations, repeals only Cabinet Resolution No. 10 of 2019 and provisions that conflict with it (art. 70).
Every range in the CR 71/2024 list sits inside the AED 10,000 to AED 5,000,000 range of art. 17. MoET lists CR 71/2024 among the AML legislation on its website, next to FDL 10/2025 and CR 134/2025.
The list will be replaced at some point: art. 39 of FDL 10/2025 tells the Cabinet to issue a new resolution on violations, administrative penalties and the grievance procedure. Until then, note that the list cites article numbers from the old Executive Regulations. They no longer match CR 134/2025, although most of the duties they refer to appear in CR 134/2025 too.
Criminal penalties that apply to brokers
| Offence | Penalty | Article |
|---|---|---|
| Money laundering | 1 to 10 years’ imprisonment and a fine of AED 100,000 to AED 5,000,000, or the value of the criminal property if higher | 26(1) |
| Money laundering using influence or authority from your position or professional activity | Temporary imprisonment and a fine of AED 1,000,000 to AED 10,000,000, or twice the value of the property if higher | 26(2) |
| Not filing a suspicious transaction report, deliberately or through gross negligence | Imprisonment and/or AED 100,000 to AED 1,000,000 | 28 |
| Tipping off a customer or anyone else about a report or an investigation | Imprisonment and/or at least AED 50,000 | 29(1) |
| Dealing in funds when there are sufficient indications that their source is illegitimate or that the beneficial owner is being concealed | At least 3 months’ imprisonment and/or at least AED 50,000 | 30(1) |
| Working as a DNFBP without the licence or registration art. 20 requires | Imprisonment and/or AED 200,000 to AED 10,000,000 | 32 |
| Breaching targeted financial sanctions instructions | Imprisonment and/or at least AED 20,000 | 33 |
The company pays separately. If any of the offences in arts. 28, 29, 30, 32, 33, 34 or 35 is committed on the company’s behalf or in its name, the company faces a fine of AED 200,000 to AED 10,000,000 (art. 27(2)). If money laundering is committed on its behalf, the fine is AED 5,000,000 to AED 100,000,000, or the value of the criminal property if higher (art. 27(1)), and the court can order the company dissolved and its premises closed (art. 27(4)).
The manager can be punished personally. The person who actually runs the company faces imprisonment and/or a fine if it is proven that they knew of the offence and that it happened because they breached the duties of their position (art. 27(5)). If a foreigner is sentenced to prison for money laundering or any felony under the law, the judgment must also order their deportation (art. 36(1)).
A business that files a report in good faith carries no criminal, civil or administrative liability for doing so, even if it wasn’t sure a crime had taken place (art. 37(1)).
What MoET inspections found
MoET publishes its inspection results. The most recent figures, for the first half of 2025, were released on 24 July 2025:
| Sector | Violations | Fines |
|---|---|---|
| Real estate brokerages | 495 | AED 18.5 million |
| Dealers in precious metals and stones | 473 | AED 20 million |
| Corporate service providers and auditors | 95 | over AED 4 million |
| All DNFBPs supervised by MoET | 1,063 | over AED 42 million |
Brokers had the most violations of the sectors MoET listed. In the first quarter of 2023 the Ministry of Economy (as it was then called) inspected 840 companies and found 831 violations; 40 real estate brokerages accounted for 25 per cent of them and were fined AED 16.5 million. In August 2023 it suspended 50 DNFBPs for three months for not registering on goAML, with the suspension kept in place until they registered.
What inspectors find most often
MoET’s releases and its sector guidance point to the same weak spots:
- Customer due diligence. The Q1 2023 release lists not verifying the identity of the customer and the beneficial owner. The March 2026 guidance for brokers reports inconsistent CDD across the sector.
- Risk assessment. Not identifying the risks of the business was a listed violation in 2023, and “risk assessment methodologies” were named again in the H1 2025 release.
- Sanctions screening. The 2023 release lists not checking customers and transactions against the terrorism lists.
- Suspicious transaction reporting. Both releases mention it: not filing STRs while carrying out CDD in 2023, and reporting mechanisms in 2025.
- PEPs and foreign clients. The guidance reports limited scrutiny of politically exposed persons and gaps in ongoing monitoring of non-face-to-face and foreign clients.
- Records. The guidance names gaps caused by manual processes and informal communication channels, which leave a broker unable to show its compliance during an inspection.
The guidance adds that when a customer pushes for a fast completion, checks get deferred or done superficially.
How to prepare for an MoET inspection
MoET inspects both on-site and off-site, and decides how often to inspect a business based on the National Risk Assessment and the business’s own risk profile (CR 134/2025, art. 49). The NRA rates the real estate sector’s inherent risk as high, as MoET’s guidance for brokers notes. You can be asked for your risk assessment (FDL 10/2025, art. 19(1)(a)) and your records (art. 19(1)(f)) at any time, so have these ready before anyone calls:
- A current AML policy that cites FDL 10/2025 and CR 134/2025 and is approved by senior management (line 1).
- A documented enterprise-wide risk assessment that takes the National Risk Assessment into account and has been reviewed recently (lines 5 and 7).
- A complete file for every deal: ID verified, beneficial owner identified, purpose of the deal and source of funds recorded, PEP and sanctions screening results with dates (lines 9, 11, 18 and 34).
- Evidence of enhanced due diligence on every high-risk customer (line 15).
- Your registrations: goAML, with the right Compliance Officer as administrator, and EOCN notifications (lines 23 and 33). The steps are in goAML registration in the UAE.
- A written Compliance Officer appointment showing the person has the competence and the means to do the job (lines 24 and 25).
- A reporting log of the STRs and REARs you filed, and the reasons for any decision not to report.
- Records kept for at least five years from the completed deal or the end of the relationship, organised so you can produce them quickly (CR 134/2025, art. 25; line 26).
MoET’s guidance also recommends periodic internal reviews and file testing to check that the policy is applied in practice. Running one before an inspection shows you the gaps first. The full set of obligations is in our guide to AML for real estate agents in the UAE.
How to object to an AML fine
CR 71/2024 sets out a grievance procedure (art. 4):
| Step | Rule |
|---|---|
| Notice | The Ministry notifies you of its decision to impose the fine within 20 working days |
| Grievance | You file a grievance with the Minister or the Minister’s delegate within 30 working days of the notice or of learning of the penalty |
| What to include | Your reasons and all supporting documents, following the Ministry’s procedures |
| Outcome | The Minister can reject the grievance, replace the penalty with another one proportionate to your activity and transaction volume, or cancel it if the grounds for the violation are removed or invalid. A grievance can’t make your position worse |
| Decision | The decision on the grievance is final. No reply within 40 working days counts as a rejection |
| Further challenge | A further appeal against the fine is not accepted until you have filed a grievance and it has been decided, or the 40 days have passed |
Fines are paid online. MoET sends the violation notice by email with the details, the amount and a payment link; you pay through the MoET website or app using the Financial Penalty Reference Number. MoET’s service page does not give a payment deadline.
What we can do
Most lines in the fine list are about documents and checks: a policy, a risk assessment, a screened customer, a filed report. Our AML subscription for real estate brokers covers that work. We register you on goAML and with the EOCN, give you an AML documentation set updated to FDL 10/2025 and CR 134/2025, screen up to 100 clients, check deals, monitor your clients on an ongoing basis and prepare up to 10 FIU reports, which your Compliance Officer then submits. You work with one personal manager, and inspection support is available on request as an extra.
It costs AED 12,000 + VAT a year or AED 3,750 + VAT a quarter, with a 10-business-day money-back guarantee on the first payment. We don’t act as your Compliance Officer, and the final call on any report stays with them.
This guide is general information, not legal advice.
What this means for you
Every gap an inspector finds can carry its own fine. Three things to know:
Fines are counted per violation
The law allows AED 10,000 to AED 5,000,000 for each violation, and Cabinet Resolution 71/2024 sets a range for each of 41 violations, so several gaps add up.
Criminal liability reaches people
Not filing an STR, tipping off and operating unregistered are crimes, and a manager who knew of the offence and breached their duties can be punished personally.
You can object in 30 working days
A grievance goes to the Minister with reasons and documents. The decision is final, and silence for 40 working days counts as a rejection.
Frequently asked questions
What are the AML fines in the UAE?
A supervisor can fine a business AED 10,000 to AED 5,000,000 for each violation (Federal Decree-Law 10/2025, art. 17). For DNFBPs supervised by MoET, Cabinet Resolution 71/2024 sets a minimum and maximum for each of 41 violations, mostly between AED 50,000 and AED 1,000,000.
What is the fine for not registering on goAML?
AED 50,000 to AED 200,000 under line 23 of the Cabinet Resolution 71/2024 list. In 2023 the Ministry of Economy also suspended 50 DNFBPs for three months for not registering on goAML.
Is Cabinet Resolution 71 of 2024 still valid under the new AML law?
Yes. Decree-Law 10/2025 keeps resolutions issued under the 2018 law in force as long as they don’t conflict with it, until they are replaced (art. 41(3)), and MoET still lists CR 71/2024 among its AML legislation.
What happens if the same AML violation is repeated?
If the same violation recurs within a year of the previous fine, the supervisor can impose an increased fine (art. 17(3)). CR 71/2024 also allows the Ministry to double the fine for a repeated violation (art. 5(2)).
How do I object to an MoET AML fine?
File a reasoned grievance with the Minister or the Minister’s delegate within 30 working days of the notice, with all supporting documents (CR 71/2024, art. 4). The decision is final, and no reply within 40 working days counts as a rejection.
What is the penalty for money laundering in the UAE?
1 to 10 years’ imprisonment and a fine of AED 100,000 to AED 5,000,000, or the value of the criminal property if higher (art. 26). A company in whose name it is committed faces AED 5,000,000 to AED 100,000,000 (art. 27(1)).
Can a broker’s manager be punished personally?
Yes. The person who actually manages the company can be imprisoned and/or fined if it is proven that they knew of the offence and that it resulted from a breach of their duties (art. 27(5)).
How much were real estate brokers fined in MoET inspections?
In the first half of 2025 MoET recorded 495 violations by real estate brokerages and AED 18.5 million in fines, out of 1,063 violations and over AED 42 million across all DNFBPs it supervises.
