In 2025, the UAE continues to strengthen its position as a global financial and investment hub. With growth, however, comes responsibility—especially for DNFBPs (Designated Non-Financial Businesses and Professions) such as real estate brokers, accounting firms, dealers in precious metals, auditors, corporate service providers, and trust companies. These sectors remain key targets for money laundering due to their high-value transactions and relatively diverse regulatory environments.

To protect the UAE economy, the government has tightened AML/CFT (Anti-Money Laundering and Combating the Financing of Terrorism) rules, making compliance a priority for all DNFBPs. Many businesses, therefore, rely on specialized accounting and audit firms—such as Swenta—to implement, monitor, and maintain strong AML frameworks.

This guide explains why DNFBPs are under strict scrutiny in 2025, why real estate remains a high-risk sector, and how a risk-based approach helps, along with practical steps to ensure compliance.

Why Real Estate Is a Prime Target for Money Laundering

Real estate continues to attract criminals for several strategic reasons:

1. High-Value Transactions

Properties allow individuals to move large amounts of money through a single purchase. A single villa or apartment can shift millions—making it an appealing tool for layering and integration.

2. Lower Oversight Compared to Financial Institutions

Unlike banks, where every transaction is heavily monitored, the real estate sector traditionally had fewer checks. This makes it easier for criminals to:

• Hide illegal funds

• Conceal beneficial owners

• Use third-party buyers or shell companies

3. Makes Tracing Difficult

Once illicit money is placed into real estate:

• It appears “clean”

• It becomes harder to confiscate

• It can be sold later, providing a seemingly legitimate source of wealth

In several countries, this unchecked activity has driven housing prices up, affected affordability, distorted markets, and damaged community structures. The impact goes far beyond financial fraud—it influences entire cities.

Understanding the Risk-Based Approach (RBA)

A Risk-Based Approach ensures that DNFBPs focus their AML efforts on the areas with the highest risk. Instead of treating every transaction equally, professionals evaluate where the major threats exist and apply enhanced safeguards.

According to FATF guidelines, all member countries—including the UAE—must ensure that industries such as real estate, accounting, and corporate service providers adopt an RBA.

This helps ensure:

• High-risk clients receive enhanced due diligence

• Unusual or suspicious patterns are flagged

• Resources are allocated efficiently

AML consultants and accounting firms in Dubai, including Swenta, play a major role in helping DNFBPs implement this approach properly.

Key RBA Steps for Real Estate & Other DNFBPs

To comply with UAE AML laws and follow global best practices, professionals must implement the following measures:

1. Conduct KYC (Know Your Customer)

Verify the identities of:

• Buyers

• Sellers

• Agents

• Ultimate Beneficial Owners (UBOs)

This prevents criminals from hiding behind layers of intermediaries.

2. Understand the Transaction Purpose

Ask critical questions:

• Is the price unusually high or low?

• Is the deal structured in a complex way without clear reason?

• Does the client refuse to provide documentation?

Any unusual or unexplained behavior should be investigated.

3. Trace the Source of Funds

Professionals must understand:

• Where the money is coming from

• Whether cash payments or offshore transfers are involved

• If the transaction pattern matches the customer profile

High-risk payments require enhanced checks.

4. Monitor Ongoing Relationships

AML compliance is not a one-time activity—ongoing monitoring is required for repeat clients. Changes in patterns or behavior must be recorded and reviewed.

5. Seek Expertise from AML Consultants

Many DNFBPs rely on AML advisors and accounting firms to:

• Establish AML policies

• Create due diligence checklists

• Analyze suspicious patterns

• Assist in goAML reporting

Swenta assists businesses by building practical and compliant AML frameworks tailored to each DNFBP category.

The Role of Supervisors and Regulators in the UAE

Real estate agents and DNFBPs are not alone in the fight against financial crime. Regulatory authorities must ensure professionals understand and apply AML controls. In the UAE, this responsibility is led by:

AMLD – Anti-Money Laundering and CFT Supervision Department

Established under the Central Bank of the UAE (CBUAE), the AMLD has been actively strengthening AML/CFT controls across all sectors since 2020.

Their tasks include:

• Conducting inspections

• Issuing guidelines

• Providing training

• Monitoring compliance

• Enforcing penalties

Sectors with limited AML maturity or weak controls require additional oversight to prevent exploitation.

Extra Attention for Weak or Developing Real Estate Markets

Emerging or rapidly growing property markets are particularly vulnerable. Supervisors focus on:

• Newly registered brokers

• Agencies with minimal AML awareness

• Regions with lax enforcement histories

By improving training and oversight, regulators help stabilize these markets and reduce exposure to criminal activity.

Practical AML Compliance Steps for DNFBPs in 2025

To strengthen compliance and reduce risk, DNFBPs should:

• Develop clear and structured due-diligence checklists

• Implement automated tools to flag unusual transactions

• Train staff regularly and document all training

• Establish internal escalation procedures for red flags

• Conduct continuous monitoring—not just initial checks

• Work with experienced AML consultants or firms like Swenta

These actions ensure businesses stay compliant while protecting themselves from hefty fines and reputational damage.

As the UAE intensifies its AML/CFT enforcement in 2025, DNFBPs must elevate their compliance standards. Real estate, accounting, corporate services, and other high-value sectors play a crucial role in safeguarding the financial system from exploitation.

Implementing a strong risk-based approach, improving due diligence, and partnering with experienced accounting/AML specialists—such as Swenta—ensures businesses remain compliant, competitive, and protected.