What Federal Decree-Law No. 10 of 2025 Requires for UAE Real Estate DNFBPs

What is Federal Decree-Law No. 10 of 2025?

Federal Decree-Law No. 10 of 2025 is the UAE's updated Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) framework. It broadens the scope of Designated Non-Financial Businesses and Professions (DNFBPs) under the law to include all real estate developers, brokerages, property managers, and contractors operating in the UAE — not a subset of large or licensed firms, but the sector as a whole.

Who counts as a DNFBP under this law?

Under Federal Decree-Law No. 10 of 2025, DNFBP status extends to real estate developers (including off-plan sales), real estate brokerages (RERA/DARI-licensed agencies and individual brokers), property management companies, and contractors and construction firms engaged in relevant transactions. Each of these categories is now subject to the same class of AML/CTF obligations previously associated mainly with licensed financial institutions.

What does the law require, operationally?

Federal Decree-Law No. 10 of 2025 mandates that in-scope DNFBPs perform, for every qualifying transaction: Know Your Customer (KYC) verification at onboarding, Customer Due Diligence (CDD) as a baseline risk assessment, Enhanced Due Diligence (EDD) automatically triggered for higher-risk buyers or transactions, Ultimate Beneficial Owner (UBO) resolution for corporate counterparties, and sanctions/PEP screening before a transaction closes.

Know Your Customer (KYC) at onboarding

Verified identity for every buyer, tenant, or vendor before a transaction proceeds.

Customer Due Diligence (CDD)

A baseline risk assessment applied to every qualifying relationship, not just flagged ones.

Enhanced Due Diligence (EDD)

A deeper review automatically triggered for higher-risk buyers, higher-risk jurisdictions, or transactions above defined value thresholds.

Ultimate Beneficial Owner (UBO) resolution

Identifying the real individual(s) who ultimately own or control a corporate buyer or counterparty, not just the entity named on the paperwork.

Sanctions and PEP screening

Checking every counterparty against sanctions and politically-exposed-person watchlists before the transaction closes.

What changed compared to the previous framework?

The most significant operational change is scope: obligations that used to sit mainly with banks and larger regulated entities now apply across the real estate value chain — developer, broker, property manager, and contractor alike. The law also introduces stricter penalties for non-compliance, raising the cost of treating AML/CTF as optional or manual paperwork.

Does Federal Decree-Law No. 10 of 2025 apply to individual brokers, or only large agencies?

It applies to the DNFBP categories above as a class — RERA/DARI-licensed brokerages and their brokers fall within scope, not only large firms.

Is UBO resolution required for every buyer, or only corporate buyers?

UBO resolution is specifically about identifying the real owner(s) behind a corporate or entity buyer/counterparty. Individual buyers are subject to standard KYC/CDD; the UBO obligation applies where a company or other legal entity is the counterparty.

What triggers Enhanced Due Diligence (EDD)?

EDD is triggered by higher-risk buyer profiles, higher-risk jurisdictions of origin, or deal values above defined thresholds — it is an escalation on top of standard CDD, not a replacement for it.