Real Estate Activity Report (REAR) submission by real estate brokers and agents and law firms as per Circular Number: 05/2022
Table of Contents
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REAR At a Glance
- What it is: REAR is a regulatory report filed on the goAML portal for certain freehold real estate transactions to support UAE AML, CFT and CPF compliance.
- Who must file: Real estate brokers and agents, and lawyers, notaries and other independent legal professionals when they prepare, conduct, or execute property purchase or sale transactions for clients.
- Main trigger: Filing becomes mandatory where a freehold property transaction involves cash payments of AED 55,000 or more (single payment or cumulative instalments).
- Virtual assets trigger: REAR is also required if payment is made in virtual assets, or using funds converted from virtual assets, whether in part or in full.
- Why it matters: REAR strengthens transparency and traceability, helping regulators and the FIU spot ML/TF/PF patterns over time, even where the transaction does not look suspicious at first glance.
- Non-compliance risk: Failure to file can expose firms to serious regulatory action, including substantial fines and potentially restrictions, suspension, or licence cancellation, depending on the supervisory authority’s powers.
Submitting Real Estate Activity Report (REAR) is a vital Anti-Money Laundering (AML), Counter-Financing of Terrorism (CFT) and Counter Proliferation Financing (CPF) compliance measure for Real Estate sector-specific Regulated Entities in UAE.
Explore how an effective REAR framework supports regulatory compliance, understand its key requirements, and follow the reporting process step by step.
What is Real Estate Activity Report (REAR)?
Real Estate Activity Report (REAR) is a Regulatory Report that licensed Real Estate Brokers, Agents and Lawyers in UAE are required to submit when they come across freehold property transactions in cash (equal to or exceeding AED 55,000) or virtual assets or funds converted from virtual currencies.
The Rational behind REAR filing is to ensure accountability, transparency and regulatory oversight within the real estate sector is maintained.
The primary purpose is to make sure property transactions that involve significant cash or virtual assets are properly reported and documented so that the related ML/FT/PF risks can be countered effectively.
Who Needs to File REAR in UAE?
Businesses in the Real Estate sector that are involved in activities that fall under the covered activities for AML/CFT/CPF compliance, as classified in Article 3.2 of Cabinet Decision No. (134) of 2025 have a compliance obligation to file REAR.
Real Estate Sector-specific Regulated Entities are mandated to file REAR when they undertake specified transactions or arrangements pertaining to the purchase or sale of real estate properties for their customers.
- Real Estate Brokers
- Real Estate Agents
- Lawyers, Notaries and other independent legal professionals, when preparing, conducting or executing financial transactions of real estate property purchase or sale for their customers.
When to File a REAR?
The obligation to submit REAR arises when Real Estate Brokers, Real Estate Agents and other legal professionals are involved in transactions that meet the following specific criteria for reporting:
The transaction is related to freehold real estate, and the mode of payment for such property transactions has been carried out in one of the following ways; then REAR must be reported without a doubt.
- The payment for the purchase or sale of such freehold property has been made in a single cash transaction that equals or exceeds AED 55,000.
- The payment for the purchase or sale of such freehold property has been made in several cash transactions whose aggregate value equals or exceeds AED 55,000.
- The entire or a portion of the payment for the purchase or sale of such freehold property has been made in virtual assets.
- The entire or a portion of the payment for the purchase or sale of such freehold property has been made in funds that are converted from virtual assets.
If the above criteria are met, then filing the Real Estate Activity Report on the goAML portal becomes obligatory.
What are Freehold Property Transactions in UAE?
Freehold property transactions in the UAE are real estate deals that allow buyers absolute ownership of the land and its unit, regardless of their nationality. It allows immigrants to buy, sell or lease properties without any restrictions in designated zones or investment zones.
The Real Estate Regulatory Authority (RERA) regulates and oversees real estate market activities and participants.
If Real Estate Brokers or Agents in UAE are facilitating these freehold property transactions, then they are subject to REAR Regulatory Reporting requirements when specific criteria are met as part of their AML/CFT/CPF obligations.
Legal Obligations for Filing REAR
Ministry of Economy and Tourism Circular Number: 05/2022 on Real Estate Activity Report is the primary legal mandate explicitly introducing reporting of REAR for licensed Real Estate Brokers and Agents in the UAE. It comprehensively specifies which transactions need to be reported and when.
As per Article 3 of Cabinet Decision No. (134) of 2025, Real Estate Brokers and Agents are classified as Designated Non-Financial Businesses and Professions (DNFBPs) when they conduct activities relating to buying and selling real estate properties on behalf of their customers.
Similarly, Purchase and Sale of Real Estate for clients is one of the covered activities of AML/CFT/CPF compliance for Lawyers, Notaries and Other independent Legal Professionals. By virtue of this, they too are under the mandate of the Ministry of Justice’s circular no. 14 of 2022 regarding the REAR Real Estate Activity Report submission on the goAML portal when they are involved in transactions related to such activities.
Consequences of Failure to File REAR
Article 17 of Federal Decree Law No. (10) of 2025, gives power to Supervisory Authorities to impose severe penalties, including fines ranging from AED 10,000 to AED 5,000,000, potential suspension or revocation of their business license, restriction on business activities for non-compliance with any directives issued by them in connection with the AML/CFT/CPF compliance.
Accordingly, Real Estate Brokers, Agents and Legal Professionals may face regulatory penalties from their relevant Supervisory Authority if they fail to submit REAR.
Why is REAR filing Necessary for the real estate sector?
According to the MOET’s Supplemental Guidance for Real Estate Sector, the real estate sector is identified as a highly attractive sector for wrongdoers to launder their illicit funds, which necessitates reporting of REAR.
The Real Estate sector offers high-value property transactions, market stability and ease of use of intermediaries or third parties. These factors provide money launderers a chance to obscure the origin of their illegally obtained money in the guise of expensive property transactions, often using intermediaries to hide true ownership.
The Real Estate Activity Report (REAR) is a preventive compliance measure introduced by the Ministry of Economy and Tourism (MOET) and the Ministry of Justice (MOJ) to close these gaps.
Through REAR, the mandatory reporting of specified transactions that are deemed to be at high risk due to involvement of large cash volumes or virtual assets ensures that they are brought under the eyes of Regulators as a preventive measure.
Moreover, REAR facilitates transparency for the FIU to perform data analysis. Even if the transaction does not appear suspicious initially, the REAR provides necessary data trails that allow Regulatory Authorities to detect complex ML/TF/PF patterns over time.
Common Challenges Faced by the Real Estate Sector in Filing REAR
The common challenges faced by the real estate sector in filing REAR include detecting transaction thresholds, confusion with different reporting requirements, complex investigations, counting multiple linked transactions, dilemmas in property classification, lack of skilled resources, inconsistent escalation process and technical difficulties.
Detecting Transaction Thresholds
Many Real Estate sector-specific Reporting Entities and law firms often struggle to identify when a transaction crosses the REAR reporting threshold of AED 55,000, especially when payments are made in parts.
Without a robust transaction monitoring tool, there is a high risk of reportable cases being missed.
Confusion with Different Reporting Requirements
There are various Regulatory Reports in UAE for AML/CFT/CPF compliance, and each regulatory report has different reporting requirements.
A lot of Real Estate Brokers and Agents get confused between when to file REAR and when other reports, such as SAR/STR, CNMR/PNMR, need to be filed. Further, the filing of REAR does not in any way exempt them from their responsibility of filing SAR, STR, CNMR, PNMR, HRC, or HRCA. Many real estate brokers and lawyers fail to understand this.
Complex Investigations
Some property transactions involve a layered ownership structure, third party involvements, and unusual payment arrangements.
Reviewing and understanding the details of complex financial transactions can be time-consuming and difficult.
Dilemmas in Property Classification
REAR is filed for freehold property transactions. However, a lot of Real Estate Agents and Brokers face problems determining whether a property qualifies as a freehold or falls under another category.
This confusion can lead to either a failure to file a mandatory REAR or the submission of redundant data for non-regulated property types.
Lack of Skilled Resources
Another major problem in submitting REAR is that not all Real Estate Agents and Brokers have dedicated compliance staff who understand the intricacy of AML/CFT/CPF obligations.
This can increase the risk of errors or missed reporting, subjecting them to regulatory penalties.
Inconsistent Escalation Process
Many of the Reporting Entities have inconsistent or outdated procedures in place for escalating reportable transactions.
Without a standardised internal escalation path, critical data often gets lost rather than being reported.
Technical Difficulties in goAML
REAR is filed via the goAML portal; however, Real Estate sector-specific Reporting Entities often struggle to deal with the technicalities of this platform.
The struggle intensifies especially when they are unfamiliar with REAR’s format, data fields and submission steps. This can slow down reporting and increase the risk of compliance failures.
Implementing Effective REAR Filing Across UAE: Step-by-Step Guide for the Real Estate Sector and Lawyers to Submit REAR
Implementing Effective REAR filing demands a structured approach and chronological process from Real Estate Regulated Entities.
The process of filing an accurate Real Estate Activity Report (REAR) involves identifying REAR-specific reporting transactions, obtaining significant documents (Emirates ID, Passport copy, Trade License, invoices, sale agreements), logging into goAML portal, selecting the REAR report type, entering mandatory information and uploading relevant documents pertaining to the transaction.
Identifying REAR Specific Reporting Transaction
The first step begins with identifying REAR-specific reporting transactions.
As explicitly stated by MOET and MOJ, when the purchase or sale of freehold real estate is carried out in cash (that equals or exceeds AED 55,000) or virtual assets or funds converted from virtual assets, the obligation to file REAR arises.
Obtaining and Recording Significant Documents
The second step is to obtain and record significant documents post-identifying a reportable transaction.
This includes collecting identification and real estate transaction-related documents. The following are the mandatory documents that Reporting Entities need to obtain and record before filing REAR.
- Identification documents of the purchaser and seller.
– For natural person: Emirates ID or Passport Copy
– For legal person: Trade License, MOA/AOA, Emirates ID or Passport copy of Ultimate Beneficial Owners (UBOs), Register of UBOs. - Receipts, Invoices and Contracts
- Purchase and Sale Agreement
Accessing the goAML Portal
The next step is to access the FIU goAML portal after obtaining and recording significant documents.
Real Estate sector-specific Reporting Entities need to log in to their goAML portal with credentials given at the time of their registration.
For Reporting Entities, it is very important to ensure that the passwords are updated and their organisational profile on the goAML portal is current.
Selecting REAR from the Dropdown Menu
The following step for Reporting Entities is to select the REAR report type from the given dropdown menu.
Post logging into the goAML portal, click on the “Web Report” tab, navigate to the report type dropdown menu and select Real Estate Activity Report (REAR) from the list of reports given.
While selecting the report type, Reporting Entities need to ensure that they do not get confused between the SAR/STR and REAR. Selecting the correct Report type is critical for an efficient REAR submission.
Entering Mandatory Data
The subsequent step for Reporting Entities is to enter mandatory data fields on the goAML portal before submission.
These data fields are mainly related to the information pertaining to the parties involved in the reportable transaction, transaction details, and property description.
Entering the names of the buyer and seller along with their nationalities and ID numbers, detailing the date, total value of the property and amounts paid in cash or virtual assets and describing the exact address and property type of the real estate in question, fulfils the essentials of REAR submission for Regulated Entities.
Uploading Relevant Documents
Post entering the mandatory details, the next step for Reporting Entities is to upload relevant documents and click submit to complete the final process.
Attachments pertaining to scanned copies of ID documents, payment receipts, invoices, contracts, and purchase and sale agreements need to be uploaded along with the report. While uploading the attachments, Reporting Entities should ensure the file size meets the goAML portal’s requirements.
After completing each step, click on the submit button to file the REAR to UAE Financial Intelligence Unit (FIU UAE).
Post-Filing Actions
The final step for Regulated Entities after filing REAR is to retain and maintain a submission copy of REAR and its supporting documents for at least 5 years, subject to the obligations of record-keeping under the UAE’s AML/CFT/CPF regulations.
Best Practices for REAR Submission
Real Estate Activity Report filing is not just a generic compliance obligation, but it safeguards the financial system from any kind of potential ML/TF/PF risks arising out of high-value property transactions.
Regulated Entities in the Real Estate sector and legal professionals must maintain accuracy and timeliness in filing REAR by adopting best practices. These best practices include implementing advanced transaction monitoring tools, updating policies and procedures, imparting training, standardising documentation, and maintaining clear audit trails for REAR reporting.
Implement Advanced Transaction Monitoring Tools
Regulated Entities in the real estate sector and lawyers must implement advanced transaction monitoring tools that can identify reportable transactions quickly and accurately.
These tools can track payment patterns, detect linked transactions, and flag cases that cross reporting thresholds. Automation reduces manual errors, saves time, and ensures that no reportable transaction pertaining to REAR is missed.
Outline a Clear Escalation Path for REAR in Policies and Procedures
Reporting Entities must define a clear escalation path for REAR reporting in their internal AML/CFT/CPF policies and procedures.
Articulation of who reviews, approves and files REAR when a reportable transaction is identified ensures that cases are handled swiftly and consistently.
Moreover, well-documented policies and procedures demonstrate readiness during regulatory inspections.
Impart Training and Awareness
Real Estate sector-specific Reporting Entities and lawyers must provide regular training and awareness to their employees regarding REAR filing requirements.
Consistent training ensures that staff understand the obligations to file REAR, its reporting thresholds, and red flag indicators.
Moreover, Reporting Entities should also train their employees on how to navigate the goAML platform and technicalities pertaining to that portal, as ultimately, they must go and file the report there only.
Standardise Documentation Procedure
Reporting Entities must ensure that they have standardised documentation procedures in place.
Adopting uniform documentation checklists ensures that all necessary information is collected for every transaction. This improves accuracy, reduces major omissions, and speeds up report preparation.
Establish a Clear Audit Trail
Regulated Entities in the Real Estate Sector must establish a clear audit trail of REAR filing. Clear records of transaction reviews, decisions, and REAR submission must be maintained.
A strong audit trail supports preparedness during regulatory inspections and showcases thorough compliance with the AML/CFT/CPF obligations of the real estate sector to regulatory authorities.
Need Help in Implementing These Best Practices?
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Documentation Requirement for REAR
| Documents to be obtained for buyer and seller, if | ||
| Individual | Corporate | |
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REAR - An Additional Reporting
It is important to note that filing of REAR to report the transaction pertaining to freehold property is an additional requirement.
Real estate brokers /agents and lawyers are also required to file Suspicious Transaction Report / Suspicious Activity Report / Fund Freeze Report / Partial Name Match Report, as and when the same are applicable. Accordingly, along with filing of reports as prescribed earlier for reporting of sanctions or suspicion, additional REAR is to be filed to report all freehold property related transactions as prescribed above.
Summary of compliance requirements for Real Estate Activity Report (REAR)
It is important to note that filing of REAR to report the transaction pertaining to freehold property is an additional requirement.
Real estate brokers /agents and lawyers are not absolved from filing of Suspicious Transaction Report / Suspicious Activity Report / Fund Freeze Report / Partial Name Match Report, as and when the same are applicable. Accordingly, along with filing of reports as prescribed earlier for reporting of sanctions or suspicion, additional REAR is to be filed to report all freehold property related transactions as prescribed above.
Transaction | Mode of payment (for a portion or entire property) | Actions by Real Estate Brokers/ Agents & Lawyers | Documents to be obtained | |
Individual | Corporate | |||
Purchase and sale transactions of Freehold Real Estate | Physical cash equal or exceeding AED 55,000 | Obtain & record
Submit REAR on GoAML platform |
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Virtual asset | ||||
Funds converted from Virtual asset | ||||
How AML UAE Supports Robust Submission of REAR by Mitigating Common Challenges
Real Estate sector-specific Reporting Entities in the UAE often encounter a number of issues while filing REAR. We here at AML UAE support Real Estate Agents and Brokers and legal professionals to build a robust AML/CFT/CPF compliance specifically customised to their business, which covers comprehensive solutions for efficient REAR filing.
- Issue: Reporting Entities struggle to interpret REAR requirements, thresholds and regulatory expectations, leading to missed or incorrect filing.
Solutions: AML UAE provides comprehensive AML Training on Real Estate Activity Report (REAR) requirements, thresholds and regulatory expectations in line with the UAE’s AML/CFT/CPF laws and sector-specific guidance for Real Estate businesses, lawyers and other legal professionals. - Issue: Regulated Entities do not know when or how to escalate reportable transactions for REAR due to unclear policies and procedures.
Solutions: AML UAE supports Real Estate sector-specific Regulated Entities and lawyers with its AML/CFT/CPF Policies, Controls and Procedures Documentation services to develop customised policies and procedures that define a clear escalation and reporting path for REAR submission. - Issue: Reporting Entities still rely on manual tracking to detect linked or high-risk transactions.
Solutions: AML UAE facilitates regulated entities through its AML Software Selection services by recommending solutions that are advanced and can autonomously detect high-value linked transactions. - Issue: Some Regulated Entities have an AML Compliance framework on paper; however, they still face challenges in filing REAR.
Solutions: AML UAE offers Regulated Entities, extensive reviews of the existing AML/CFT/CPF framework, identifies gaps and provides actionable recommendations through its AML/CFT/CPF Health check services.
Submit Real Estate Activity Report (REAR) Promptly and Adequately Through a Structured Approach
Timely and Accurate submission of Real Estate Activity Report (REAR) is essential for AML/CFT/CPF compliance obligation for Real Estate sector-specific Regulated Entities such as Real Estate Brokers, Agents and Legal Professionals.
Even minor gaps in identifying reportable transactions, documenting details or submitting reports can expose businesses to ML/TF/PF risks and regulatory scrutiny.
AML UAE supports Real Estate Sector Reporting Entities in simplifying the REAR reporting process through its specialised services and expert team. With the right guidance, tools and procedures in place, businesses can confidently manage their REAR obligations as per the requirements of UAE’s AML/CFT/CPF laws.
Ensure Accurate REAR Filing with Confidence
Strengthen Real Estate Sector AML/CFT/CPF Compliance with Our Expert Support and Efficient Services.
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About the Author
Pathik Shah
FCA, CAMS, CISA, CS, DISA (ICAI), FAFP (ICAI)
Pathik is an ACAMS-certified AML consultant specialising in governance, risk, and compliance for regulated entities in the UAE. He brings over 28 years of experience, with 1,000+ hours of AML training and 200+ advisory engagements across DNFBPs, VASPs, and FIs. He supports businesses in aligning with AML/CFT requirements from the CBUAE, DFSA, MoET, MoJ, VARA, CMA, FSRA, and FATF. Known for translating complex regulations into audit-ready procedures, Pathik enables operational clarity and compliance readiness.
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