Does Cabinet Resolution 134 of 2025 apply to you?

Cabinet Resolution 134 of 2025 designates certain real estate activities as subject to UAE AML/CFT obligations, but not every real estate business is captured in the same way. The applicability question turns on what the business actually does: brokering the sale or purchase of real estate falls squarely within scope, while activities such as valuation, marketing, leasing, and property management carry different — and sometimes narrower — obligations depending on how the activity is structured. Getting this determination wrong in either direction is costly: registering unnecessarily wastes time and creates ongoing filing obligations you didn't need, while failing to register when you should have exposes the firm to regulatory action. We work through your specific activity mix against the Resolution's scope before recommending a registration path.

MOEC/goAML registration and MLRO appointment

Once applicability is confirmed, registration itself involves filing with the Ministry of Economy (MOEC) and creating the entity's profile on the goAML platform used for regulatory reporting. Every registered DNFBP also needs a designated Money Laundering Reporting Officer (MLRO) — the individual accountable for the firm's AML program and its regulator-facing filings. We guide firms through both the registration filings themselves and the practical question of who within the business is positioned to take on the MLRO role.

AML/CFT policy manual drafting

A registered DNFBP needs a written AML/CFT policy manual describing how the business identifies, assesses, and manages money-laundering risk — not a generic template, but a document that reflects how your firm actually transacts. A typical policy manual we draft for a client covers:

• AML/CFT governance structure and MLRO responsibilities
• Customer due diligence and enhanced due diligence procedures
• Screening, monitoring, and escalation workflows
• Record-keeping standards and retention periods
• Suspicious activity reporting and internal escalation paths
• Staff training and annual review requirements

We don't publish sample policy manuals on this site — the content is specific to each client's risk profile and would be misleading as a generic example. A full outline of what a policy manual covers is available on request during a scoping call.

Annual review and gap-assessment audits

Policies age. Regulatory guidance shifts, business activities expand, and a manual written for a five-person brokerage doesn't necessarily still fit once the firm has grown or diversified. We run annual gap-assessment audits against current obligations and update the policy manual so it stays a document a regulator can rely on, not one that was accurate the year it was written.