goAML Reports for Real Estate Brokers: REAR, STR, SAR, HRC, CNMR and PNMR
A UAE real estate broker files five kinds of reports on goAML: a REAR for cash and crypto deals, an STR or SAR when something looks suspicious, an HRC or HRCA for high-risk countries, a CNMR or PNMR for a sanctions match, and replies to the FIU’s requests. Each has its own trigger and deadline, and only the REAR is filed whether or not anything looks wrong.
This guide explains when each report applies, how fast it is due, who files it, and what happens if you don’t. If your brokerage is not on goAML yet, start with goAML registration in the UAE.
The reports at a glance
| Report | When you file it | Deadline | Goes to |
|---|---|---|---|
| REAR (Real Estate Activity Report) | Freehold sale or purchase with physical cash of AED 55,000 or more, or with any payment in virtual assets | No number of days is published. File it as part of closing the deal | FIU |
| STR (Suspicious Transaction Report) | You suspect a transaction or funds are linked to a crime, whatever the amount | Without delay | FIU |
| SAR (Suspicious Activity Report) | Suspicious activity, or an attempted deal that never went ahead | Without delay | FIU |
| HRC / HRCA (High Risk Country) | A transaction (HRC) or activity (HRCA) linked to a country on the UAE’s high-risk list | Before the deal. You may proceed after 3 working days if the FIU hasn’t objected | FIU |
| CNMR (Confirmed Name Match Report, formerly FFR) | A confirmed match with the UAE or UN sanctions lists | Freeze within 24 hours, report within 5 business days | EOCN and MoET |
| PNMR (Partial Name Match Report) | A possible sanctions match you can’t confirm or rule out | Suspend without delay, report within 5 business days | EOCN and MoET |
| AIF / RFI | The FIU asks you for information | By the date in the request | FIU |
Interactive check
Six quick questions about one sale or purchase. Your answers are not stored or sent anywhere.
General information, not legal advice. The tool does not replace the decision of your Compliance Officer.
REAR: the threshold report every broker files
The Real Estate Activity Report (REAR) is the report brokers file most often. MoET Circular No. 5 of 2022 requires it for a freehold purchase or sale when:
- the customer pays AED 55,000 or more in physical cash, in one payment or several, for all or part of the price;
- any part of the price is paid in virtual assets (crypto); or
- the funds were converted from virtual assets for all or part of the price. MoET’s 2026 guidance for brokers words this as converted “from or to” a virtual asset.
A REAR is not a suspicion report. You file it even when the customer checks are complete and nothing looks wrong. MoET’s guidance says the obligation “is not risk-dependent”.
Common questions:
- An international bank transfer from an individual? No REAR on that alone (FIU Reports FAQ).
- A lease? Brokers fall under the AML law for purchases and sales of real estate (CR 134/2025, art. 3(2)), and the REAR covers freehold purchases and sales only.
- A cash or crypto deal that is also suspicious? File both a REAR and an STR or SAR. One doesn’t replace the other.
- Will the FIU reply? No. You don’t wait for an answer before going ahead (FIU Reports FAQ). Keep the goAML confirmation in the deal file.
- What’s the deadline? Neither the circular nor the FIU guide sets a number of days. MoET’s guidance refers to “predefined parameters and timelines” and asks you to build the REAR into payment acceptance and deal completion. So file it once the payment method and amount are known.
What to keep with it (Circular 5/2022): the customer’s Emirates ID or passport copy, receipts, invoices, contracts and the sale and purchase agreement. For a company, add its trade licence, articles of association, register of beneficial owners and the IDs of all beneficial owners and shareholders.
STR and SAR: reporting suspicion
If you suspect, or have reasonable grounds to suspect, that a transaction or funds are the proceeds of a crime or linked to one, you must notify the FIU without delay, whatever the amount (Federal Decree-Law No. 10 of 2025, art. 18; CR 134/2025, art. 18). You must also answer the FIU’s follow-up requests promptly.
STR or SAR?
- An STR concerns a transaction, such as an accepted offer or a paid deposit.
- A SAR concerns suspicious behaviour or an attempted deal that never happened, for example a buyer who walks away when you ask about the source of funds.
The FIU’s own FAQ puts the difference in terms of data: an STR needs the suspect’s bank account details and a SAR doesn’t. For one transaction you file one or the other, not both.
You don’t need proof. Reasonable suspicion is enough. Typical triggers from MoET’s 2026 guidance:
- the customer can’t or won’t explain where the money comes from;
- payments from third parties with no clear link to the buyer;
- payments split into smaller amounts over short intervals;
- a price far above or below the market with no explanation;
- the same property sold several times in a short period;
- pressure to close unusually fast;
- a buyer or seller who seems to be acting for someone else.
A single red flag calls for more questions first. If the answers don’t remove the doubt, the matter goes to the Compliance Officer.
Who decides? Your Compliance Officer reviews the information, decides whether to notify the FIU or keep the matter on file, and records the reasons in full confidentiality (CR 134/2025, art. 22(2)). Staff escalate to the Compliance Officer and don’t decide alone.
Can’t complete the customer checks? Then you must not go ahead with the deal, and you should consider an STR (CR 134/2025, art. 14).
Tipping off: what you can’t tell the customer
You must not tell the customer or anyone else that you have filed or are about to file a report, or that an investigation is under way (CR 134/2025, art. 19). Doing so is a crime: imprisonment and/or a fine of at least AED 50,000 (FDL 10/2025, art. 29(1)). So don’t tell a hesitant buyer “we have to report this to the FIU”. Say something neutral, such as “we need these documents to proceed”, and escalate internally.
HRC and HRCA: high-risk countries
If a transaction or activity is linked to a country the National Committee lists as high-risk, you file:
- an HRC for a transaction;
- an HRCA for an activity without a transaction.
Unlike the other reports, this one comes before the deal. You may proceed only after three working days, and only if the FIU hasn’t objected (FIU Reports FAQ). The list changes: MoET publishes updates by circular (the latest is Circular No. 1 of 2026), so check the current list for each deal. Customers from these countries also need enhanced due diligence (CR 134/2025, art. 23).
CNMR and PNMR: sanctions matches
You screen every customer against the UAE Local Terrorist List and the UN Security Council Consolidated List. These two reports go through goAML to the Executive Office for Control and Non-Proliferation (EOCN) and to MoET, not to the FIU.
- Confirmed match. Freeze the funds and assets without delay, and in any case within 24 hours, without warning the customer. File a CNMR within five business days of the freeze. For a prospective customer, reject the deal and file within five business days of the rejection.
- Partial match you can’t confirm or rule out. Suspend the transaction without delay and file a PNMR within five business days. Keep everything on hold until the EOCN replies through goAML.
The CNMR was called the Funds Freeze Report (FFR) until the EOCN’s July 2025 update, and older guides still use that name. Matches on foreign lists such as OFAC or the EU’s don’t go in a CNMR or PNMR. The full process, with the EOCN’s deadlines, is in our sanctions screening guide.
Replies to the FIU: AIF and RFI
The FIU sometimes writes to you through the goAML Message Board:
- an AIF (Additional Information File) asks for more detail on a report you filed;
- an RFI (Request for Information) can arrive even if you haven’t filed anything.
Answer through goAML by the date in the request. Not providing the information the FIU asks for is a separate violation on the CR 71/2024 list (line 22).
What happens if you don’t report?
| Failure | Penalty | Source |
|---|---|---|
| Not reporting a suspicion, deliberately or through gross negligence | Imprisonment and/or a fine of AED 100,000 to AED 1,000,000 | FDL 10/2025, art. 28 |
| STR not filed promptly, or information the FIU asked for not provided | Administrative fine of AED 100,000 to AED 500,000 | CR 71/2024, line 22 |
| No indicators for spotting suspicious transactions | AED 50,000 to AED 500,000 | CR 71/2024, line 21 |
| Tipping off the customer | Administrative fine of AED 100,000 to AED 500,000; as a crime, imprisonment and/or at least AED 50,000 | CR 71/2024, line 28; FDL 10/2025, art. 29(1) |
| Not reporting a sanctions match to the EOCN promptly | AED 100,000 to AED 1,000,000 | CR 71/2024, line 38 |
| Any violation of the AML law | Range set by the law: AED 10,000 to AED 5,000,000 per violation | FDL 10/2025, art. 17 |
The CR 71/2024 list was issued under the 2018 law and stays in force under Federal Decree-Law No. 10 of 2025 until a new list replaces it (art. 41(3)). It has no line that names the REAR, but MoET’s guidance warns that missing REARs can expose a broker to regulatory action. More in our guide to AML fines in the UAE.
Keep the records
Keep every report, the documents behind it and your Compliance Officer’s reasoning, including each decision not to report, for at least five years (CR 134/2025, art. 25). This is what MoET asks for at an inspection.
What we can do for you
Our AML subscription for brokers prepares the reports and leaves the decision and the submission with your Compliance Officer:
- up to 10 FIU reports a year prepared in goAML: REAR, STR or SAR, HRC or HRCA, CNMR or PNMR;
- each report ready within two business days of receiving the complete deal details;
- a sanctions match escalated the same business day, with the CNMR or PNMR ready within one business day;
- deal checks before closing, so you know which report a deal needs.
See what’s included and the price →
This guide is general information, not legal advice.
What this means for you
Reporting on goAML comes down to three habits:
File a REAR for every cash or crypto deal
Physical cash of AED 55,000 or more, or any virtual assets, on a freehold sale or purchase means a REAR, even when the deal is clean.
Report suspicion without delay
Escalate red flags to the Compliance Officer, who decides on an STR or SAR and records the reasons. Never tell the customer.
Check countries and lists before the deal
An HRC goes in before a high-risk-country deal, with three working days to wait. A sanctions match means freezing or suspending first, then a CNMR or PNMR within five business days.
Frequently asked questions
What is an STR in the UAE?
A Suspicious Transaction Report. A broker files it on goAML when they suspect, or have reasonable grounds to suspect, that a transaction or funds are linked to a crime, whatever the amount. It must be filed without delay (FDL 10/2025, art. 18).
What is the difference between an STR and a SAR?
An STR concerns a transaction. A SAR concerns suspicious behaviour or an attempted deal that never went ahead, such as a buyer who walks away when asked about the source of funds. The FIU adds that an STR needs the suspect’s bank account details and a SAR doesn’t.
What is a REAR report?
A Real Estate Activity Report. Brokers file it for freehold sales and purchases paid with physical cash of AED 55,000 or more, or paid wholly or partly in virtual assets (MoET Circular 5/2022). It is a threshold report, filed even when nothing is suspicious.
Is there a deadline for filing a REAR?
No number of days is published in MoET Circular 5/2022 or in the FIU guide. MoET’s guidance asks brokers to build the REAR into deal completion, so file it once the payment method and amount are known.
Do I need a REAR for an international bank transfer?
No. According to the FIU’s Reports FAQ, an international bank transfer from an individual doesn’t require a REAR on its own.
Can I file a REAR and an STR for the same deal?
Yes, and you must when both apply. The REAR covers the cash or crypto threshold and the STR or SAR covers the suspicion. One doesn’t replace the other.
Can I tell my customer I filed a report?
No. Telling the customer, directly or indirectly, is tipping off. It is a crime punishable by imprisonment and/or a fine of at least AED 50,000 (FDL 10/2025, art. 29).
Who submits reports in goAML?
Your Compliance Officer, who decides whether to report and submits through their own goAML login. A provider can prepare the report, but the Compliance Officer reviews and files it.
How long do I keep report records?
At least five years, together with the documents behind each report and the Compliance Officer’s reasons, including decisions not to report (CR 134/2025, art. 25).
