REAR Submission Obligation Checker
Determine whether you are required to file a Real Estate Activity Report (REAR) on the UAE FIU goAML portal, step by step.
REAR Checker
REAR Submission Obligation Checker — Assessment Report
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- real estate brokers and agents under MoET Circular No. 05/2022, and
- lawyers and law firms under MoJ Circular No. 14 of 2022,
Based on your selection, this tool does not identify your entity as falling within the REAR filing scenarios currently reflected here, namely:
- Real estate brokers and agents under MoET Circular No. 05/2022, and
- Lawyers and law firms under MoJ Circular No. 14 of 2022.
This result does not determine your broader AML/CFT obligations, which may still apply under the current UAE AML/CFT legal framework.
Other goAML Reports — Your Obligations Remain
Regulatory References
- Federal Decree-Law No. 10 of 2025 on Anti-Money Laundering, Combating the Financing of Terrorism and Financing of Illegal Organisations
- Cabinet Resolution No. 134 of 2025 issuing the Executive Regulation of Federal Decree-Law No. 10 of 2025 — Article 3(2)
- MoET Circular No. 05/2022 on the Real Estate Activity Report for real estate brokers and agents
- MoJ Circular No. 14 of 2022 on the Real Estate Activity Report for lawyers and law firms
This tool applies the current federal AML/CFT framework together with the REAR filing scenarios reflected in the above circulars, on the basis that those circulars continue to be applied unless replaced or revoked.
Need guidance on your AML/CFT obligations?
Our team can help you identify your goAML reporting requirements and ensure full compliance.
Contact AMLUAE →MoJ Circular No. 14 of 2022 applies to lawyers who are preparing, conducting or executing a financial transaction for a freehold property purchase or sale on behalf of a client. Where the engagement is limited to providing legal advice, drafting opinions, or litigation representation, REAR is not required for that specific instruction.
If the nature of your engagement changes and you proceed to execute or conduct the financial transaction itself, you must re-assess your REAR obligation at that point.
Your other AML/CFT obligations — including CDD, record-keeping, and all other goAML reports — continue to apply in full under Federal Decree-Law No. 10 of 2025 and MoJ supervisory guidelines.
Other goAML Reports — Your Obligations Remain
Regulatory References
- Federal Decree-Law No. 10 of 2025 on Anti-Money Laundering, Combating the Financing of Terrorism and Financing of Illegal Organisations
- Cabinet Resolution No. 134 of 2025 issuing the Executive Regulation of Federal Decree-Law No. 10 of 2025 — Article 3(2)
- MoET Circular No. 05/2022 on the Real Estate Activity Report for real estate brokers and agents
- MoJ Circular No. 14 of 2022 on the Real Estate Activity Report for lawyers and law firms
This tool applies the current federal AML/CFT framework together with the REAR filing scenarios reflected in the above circulars, on the basis that those circulars continue to be applied unless replaced or revoked.
Unsure about your scope of engagement?
Speak to an AMLUAE specialist to confirm whether your mandate triggers REAR or other obligations.
Contact AMLUAE →MoET Circular No. 05/2022 applies to real estate brokers and agents who are facilitating a purchase or sale transaction for a client on freehold property. If your engagement for this transaction is limited to valuation, property management, or other non-transactional services, REAR is not required for this specific instruction.
If the nature of your engagement changes and you proceed to broker or facilitate an actual purchase or sale, you must re-assess your REAR obligation at that point.
Your other AML/CFT obligations — including CDD, record-keeping, and all other goAML reports — continue to apply in full under Federal Decree-Law No. 10 of 2025 and MoET supervisory guidelines.
Other goAML Reports — Your Obligations Remain
Regulatory References
- Federal Decree-Law No. 10 of 2025 on Anti-Money Laundering, Combating the Financing of Terrorism and Financing of Illegal Organisations
- Cabinet Resolution No. 134 of 2025 issuing the Executive Regulation of Federal Decree-Law No. 10 of 2025 — Article 3(2)
- MoET Circular No. 05/2022 on the Real Estate Activity Report for real estate brokers and agents
- MoJ Circular No. 14 of 2022 on the Real Estate Activity Report for lawyers and law firms
This tool applies the current federal AML/CFT framework together with the REAR filing scenarios reflected in the above circulars, on the basis that those circulars continue to be applied unless replaced or revoked.
Need help with AML compliance for your business?
AMLUAE provides tailored AML/CFT compliance services for real estate sector entities.
Contact AMLUAE →Based on the information entered, this tool does not identify a REAR filing trigger because the transaction has not been assessed as a freehold property purchase or sale falling within the circular-based scenarios used in this tool.
This does not remove any wider AML/CFT duties, including customer due diligence, record-keeping, sanctions screening, and where relevant, other goAML reporting obligations.
Other goAML Reports — Your Obligations Remain
Regulatory References
- Federal Decree-Law No. 10 of 2025 on Anti-Money Laundering, Combating the Financing of Terrorism and Financing of Illegal Organisations
- Cabinet Resolution No. 134 of 2025 issuing the Executive Regulation of Federal Decree-Law No. 10 of 2025 — Article 3(2)
- MoET Circular No. 05/2022 on the Real Estate Activity Report for real estate brokers and agents
- MoJ Circular No. 14 of 2022 on the Real Estate Activity Report for lawyers and law firms
This tool applies the current federal AML/CFT framework together with the REAR filing scenarios reflected in the above circulars, on the basis that those circulars continue to be applied unless replaced or revoked.
Need AML compliance support?
AMLUAE provides tailored AML/CFT services for real estate sector entities in the UAE.
Contact AMLUAE →Documents and Next Steps
You should collect and retain the relevant identification and transaction documents, and proceed to complete the REAR through the UAE FIU goAML portal in accordance with your applicable circular and wider AML/CFT obligations.
Record-Keeping Obligation
- Retain all documents and information related to the transaction for a minimum of 5 years — MoET Circular No. 05/2022, Clause 6; MoJ Circular No. 14/2022, Clause 5; Cabinet Decision No. 10/2019, Article 24
Other goAML Reports — Your Obligations Also Apply
Regulatory References
- Federal Decree-Law No. 10 of 2025 on Anti-Money Laundering, Combating the Financing of Terrorism and Financing of Illegal Organisations
- Cabinet Resolution No. 134 of 2025 issuing the Executive Regulation of Federal Decree-Law No. 10 of 2025 — Article 3(2)
- MoET Circular No. 05/2022 on the Real Estate Activity Report for real estate brokers and agents
- MoJ Circular No. 14 of 2022 on the Real Estate Activity Report for lawyers and law firms
This tool applies the current federal AML/CFT framework together with the REAR filing scenarios reflected in the above circulars, on the basis that those circulars continue to be applied unless replaced or revoked.
Need help preparing and filing your REAR?
AMLUAE provides end-to-end regulatory reporting assistance including goAML REAR submission support.
Contact AMLUAE →This result is limited to the REAR assessment only. It does not remove wider AML/CFT obligations, including customer due diligence, sanctions compliance, record-keeping, and where relevant, other goAML reporting obligations.
If further payments are received or made on this transaction, you should re-assess. Cumulative cash payments that collectively reach AED 55,000 or more may trigger a REAR filing obligation under the applicable circular.
Ongoing Monitoring Required
- Monitor all future payments on this transaction. REAR becomes mandatory the moment cumulative cash reaches AED 55,000, or any virtual asset payment is received or made.
- Your STR/SAR obligation applies regardless of REAR. If any payment or behaviour appears suspicious, file an STR/SAR immediately.
- Continue to apply CDD and record-keeping requirements under Federal Decree-Law No. 10 of 2025 and applicable supervisory guidelines.
Other goAML Reports — Your Obligations Remain
Regulatory References
- Federal Decree-Law No. 10 of 2025 on Anti-Money Laundering, Combating the Financing of Terrorism and Financing of Illegal Organisations
- Cabinet Resolution No. 134 of 2025 issuing the Executive Regulation of Federal Decree-Law No. 10 of 2025 — Article 3(2)
- MoET Circular No. 05/2022 on the Real Estate Activity Report for real estate brokers and agents
- MoJ Circular No. 14 of 2022 on the Real Estate Activity Report for lawyers and law firms
This tool applies the current federal AML/CFT framework together with the REAR filing scenarios reflected in the above circulars, on the basis that those circulars continue to be applied unless replaced or revoked.
Stay compliant as payments progress
AMLUAE can help you set up monitoring workflows so you never miss a REAR filing trigger.
Contact AMLUAE →What is the REAR Submission Obligation Checker?
If you are a real estate broker, estate agent, or legal professional operating in the UAE, you may have encountered the term REAR, the Real Estate Activity Report. Introduced under the UAE’s expanding AML/CFT regulatory framework, REAR filing is a compliance obligation that catches many regulated entities off guard, particularly because it is triggered by the nature and payment mode of a transaction rather than by the total property value alone.
The REAR Submission Obligation Checker is a free, interactive, step-by-step compliance tool published by AMLUAE on amluae.com. It is designed to help real estate brokers, agents, lawyers, and compliance officers instantly determine whether a specific freehold property transaction triggers a REAR filing obligation under the applicable UAE regulatory circulars.
The tool operates within the current UAE AML/CFT legal framework established by Federal Decree-Law No. 10 of 2025 on Anti-Money Laundering, Combating the Financing of Terrorism and Financing of Illegal Organisations, and Cabinet Resolution No. 134 of 2025 issuing its Executive Regulation. The REAR filing scenarios it reflects are drawn from two operational circulars that continue to apply unless replaced or revoked:
- MoET Circular No. 05/2022 on the Real Estate Activity Report, addressed to real estate brokers and agents licensed in the UAE, and
- MoJ Circular No. 14 of 2022 on the Real Estate Activity Report, addressed to lawyers and law firms supervised by the Ministry of Justice.
Scope note:
This tool is a first-level compliance screening resource, not a substitute for legal or regulatory advice. Results should be verified against the applicable circulars and, where uncertainty exists, confirmed by independent professional review.
Why REAR Filing Matters for UAE DNFBPs
The UAE has invested significantly in strengthening its AML/CFT ecosystem since its mutual evaluation by the Financial Action Task Force (FATF). Real estate and legal sectors are among the highest-risk Designated Non-Financial Businesses and Professions (DNFBPs) globally for money laundering, particularly through high-value property transactions that can be exploited to layer and integrate illicit funds.
The REAR report is the UAE’s mechanism for capturing transaction-level data on qualifying cash and virtual asset payments in the real estate sector, submitted directly to the UAE Financial Intelligence Unit (FIU) through the goAML portal. It is operationally distinct from the Suspicious Transaction Report (STR) and Suspicious Activity Report (SAR); REAR is a transactional data report, not a suspicion-based report.
Critically, submitting a REAR does not exempt a regulated entity from also filing an STR, SAR, or other goAML reports when the relevant conditions are met. The two obligations are parallel, not alternative.
Key risk for non-compliance:
Regulated entities that fail to identify REAR filing triggers and submit in time expose themselves to supervisory action by MoET or MoJ, which supervise real estate and legal sector DNFBPs respectively. Non-compliance with AML/CFT reporting obligations may result in administrative sanctions, financial penalties, or referral for prosecution under Federal Decree-Law No. 10 of 2025.
Who Must File a REAR? Sector Coverage
REAR filing obligations currently apply to two specific categories of regulated entities in the UAE. The table below provides a clear comparison:
| Entity Type | Qualifying Activity | Governing Circular |
|---|---|---|
| Real Estate Broker / Agent | Facilitating a freehold property purchase or sale transaction for a client (brokerage or agency role) | MoET Circular No. 05/2022 |
| Law Firm / Legal Professional | Preparing, conducting or executing a financial transaction for a freehold property purchase or sale on behalf of a client | MoJ Circular No. 14 of 2022 |
| Other DNFBPs (DPMS, VASP, TCSP, etc.) | Not covered by either REAR circular, general AML/CFT obligations still apply | Federal Decree-Law No. 10 of 2025; Cabinet Resolution No. 134 of 2025 |
It is important to note that the REAR Submission Obligation Checker covers only the two circular-based regimes above. Entities in other DNFBP categories, such as Dealers in Precious Metals and Stones (DPMS), Virtual Asset Service Providers (VASPs), Trust and Company Service Providers (TCSPs), or accounting and auditing firms, are not covered by either REAR circular. Their general AML/CFT obligations under Federal Decree-Law No. 10 of 2025 continue to apply in full.
What Triggers a REAR Filing? Payment Modes and Thresholds
| Payment Mode | REAR Trigger Condition | Circular Reference |
|---|---|---|
| Physical Cash (AED) | Single or cumulative payment(s) equal to or exceeding AED 55,000 for the whole or part of the property value | MoET Circular No. 05/2022, Clause 1; MoJ Circular No. 14/2022, Clause 1 |
| Virtual Asset (crypto, etc.) | Any payment made in virtual assets for part or all of the property value, regardless of amount | MoET Circular No. 05/2022, Clause 2; MoJ Circular No. 14/2022, Clause 2 |
| Funds Converted from Virtual Asset | Funds used in the transaction recorded as having been converted from virtual assets for part or all of the property value | MoET Circular No. 05/2022, Clause 3; MoJ Circular No. 14/2022, Clause 3 |
| Cheque, Bank Transfer, Other | No REAR trigger, but other AML/CFT obligations (CDD, STR, SAR, record-keeping) continue to apply | Federal Decree-Law No. 10 of 2025; Cabinet Resolution No. 134 of 2025 |
Structuring alert:
The cash threshold applies on a cumulative basis. One or more qualifying cash payments that together equal or exceed AED 55,000 for the whole or part of the property value trigger the obligation, even if each individual instalment is below AED 55,000. Structuring payments to remain below the threshold does not remove the REAR filing obligation.
How the REAR Submission Obligation Checker Works: Step-by-Step
The tool operates as a five-step guided wizard. Each step asks a focused question and uses the answer to route the user towards the correct regulatory result. No data is stored; the tool runs entirely in the user’s browser and can be printed to PDF for record-keeping purposes.
| # | Step | What the tool asks / does |
|---|---|---|
| 1 | Entity Type (Sector) | The tool asks whether you are a real estate broker / agent, a law firm / legal professional, or another entity type. “Other” entities are immediately routed to a result confirming REAR does not apply under either circular, with a note that broader AML/CFT obligations remain. |
| 2 | Scope of Activity | Based on your sector, the tool asks you to confirm your specific role in the transaction. Brokers confirm they are facilitating a purchase or sale (not just providing valuation or management). Lawyers confirm they are executing or conducting the financial transaction (not purely advising or litigating). Entities outside the qualifying role receive a “not required for this transaction” result with appropriate caveats. |
| 3 | Freehold Property | The tool asks whether the transaction involves freehold real estate. REAR applies only to freehold purchase and sale scenarios. Non-freehold transactions (leasehold, rental, tenancy, property management) are routed to a “not triggered” result with a reminder that other AML/CFT duties continue. |
| 4 | Transaction Type | You confirm whether the transaction is a purchase, a sale, or both (exchange / swap). This contextualises the result and the document checklist. |
| 5 | Payment Transactions | This is the analytical core of the tool. You add each payment transaction individually, capturing the transaction date, reference number, buyer type (Individual / Corporate), buyer name, Emirates ID or Trade Licence, seller type, seller name, seller ID, payment mode, and amount in AED. The tool calculates the cumulative cash total and checks for virtual asset payments. A real-time threshold indicator shows whether the AED 55,000 cumulative cash threshold has been met or how far below it you currently are. |
Once you click “Check Obligation”, the tool produces one of five possible results based on your inputs. Every result includes the applicable regulatory references, a document checklist tailored to the party types entered, the parallel goAML reporting obligations that remain in force, and a print button to save the assessment as a PDF record.
How the Tool Works for Real Estate Brokers and Agents
For real estate brokers and agents supervised by MoET, the REAR obligation has been in effect since 1 July 2022 under MoET Circular No. 05/2022.
Qualifying scenario: Broker facilitating a freehold property sale
A real estate broker in Dubai is facilitating the sale of a freehold apartment in a designated freehold zone. The buyer pays a booking deposit of AED 30,000 in cash, followed by a second cash payment of AED 35,000 three weeks later.
Walking through the REAR Submission Obligation Checker:
- Sector: Real estate broker/agent
- Scope: Facilitating a freehold purchase/sale for a client (brokerage role)
- Freehold: Yes
- Transaction type: Sale
- Payments: Two cash transactions, AED 30,000 and AED 35,000, entered separately. Cumulative cash total: AED 65,000.
Result: REAR filing required. The cumulative cash total of AED 65,000 exceeds the AED 55,000 threshold for the property value (Clause 1, MoET Circular No. 05/2022). The tool generates a document checklist, identifies the record-keeping obligation (5 years), and reminds the broker that STR, SAR, and other goAML reports are separate parallel obligations.
Non-qualifying scenario: Broker in a property management role
A broker is engaged by a landlord to manage a leasehold apartment. The tool routes this transaction to a “REAR not triggered” result at Step 3 (not freehold) or at Step 2 (non-transaction role), depending on the nature of the engagement confirmed by the user.
Important for brokers:
The REAR obligation arises at the point of actual receipt or payment of qualifying funds, not at the point of signing the Sale and Purchase Agreement (SPA). A broker who receives a cash deposit before the SPA is formally executed may already have triggered the obligation.
How the Tool Works for Lawyers and Law Firms
MoJ Circular No. 14 of 2022 extended REAR filing obligations to lawyers and law firms that prepare, conduct or execute financial transactions for freehold property purchase or sale on behalf of clients. This is a meaningful distinction from purely advisory or litigation work.
Qualifying scenario: Law firm executing a property purchase
A law firm in Abu Dhabi is acting as transaction counsel for a client purchasing a freehold villa. The firm handles the client’s funds, disbursing AED 200,000 in cash as part of the deposit structure to the seller.
Walking through the REAR Submission Obligation Checker:
- Sector: Law firm / legal professional
- Scope: Preparing, conducting or executing a financial transaction for a freehold property purchase or sale
- Freehold: Yes
- Transaction type: Purchase
- Payments: AED 200,000 in cash, well above the AED 55,000 threshold.
Result: REAR filing required. The tool cites Clause 1 of MoJ Circular No. 14 of 2022 and generates the appropriate document checklist, including, for the corporate buyer, Trade Licence, Articles / constitutional documents, UBO Register, and Emirates ID or passport copies for all Beneficial Owners and shareholders.
Likely out-of-scope scenario: Lawyer providing title opinion only
A lawyer is engaged to provide a legal opinion on the title for a freehold property acquisition. The lawyer does not handle client funds, does not execute the SPA, and is not involved in the financial mechanics of the transaction.
The REAR Submission Obligation Checker routes this engagement to a “REAR submission not required for this transaction” result at Step 2, with a clear note that the result is limited to the REAR assessment and that the tool recommends independent confirmation where uncertainty exists regarding scope.
Note for legal professionals:
The scope of qualifying legal activity under MoJ Circular No. 14 of 2022 focuses on the execution and conduct of the financial transaction, not merely the provision of legal advice. If the nature of an engagement evolves during a matter, for example, if a purely advisory mandate is extended to include transaction execution, the REAR obligation should be re-assessed at that point.
Document Collection, Recording, and Retention
A key feature of the REAR Submission Obligation Checker is its dynamic document checklist. Based on the party types selected in Step 5 (buyer and seller, each confirmed as individual or corporate), the tool generates a tailored checklist of documents that must be collected, recorded, and retained as part of the transaction file.
| Party Type | Required Documents | Retention Period |
|---|---|---|
| Individual (Natural Person) Buyer or Seller | Valid Emirates ID or valid passport copy; receipts and invoices; Sale and Purchase Agreement; any related contracts | 5 years (Clause 1 Article 25; Cabinet Resolution No. 134/2025) |
| Corporate (Legal Person) Buyer or Seller | Trade Licence; Articles / constitutional documents including Memorandum and Articles of Association where applicable; UBO Register; Emirates ID or valid passport copy for all Beneficial Owners; Emirates ID or valid passport copy for all shareholders / partners | 5 years (Clause 1 Article 25; Cabinet Resolution No. 134/2025) |
These documents should be collected before or at the time of the qualifying payment, recorded accurately in the firm’s AML/CFT files, and retained for a minimum of five years in accordance with Clause 6 of MoET Circular No. 05/2022, Clause 5 of MoJ Circular No. 14 of 2022, and Article 25 of Cabinet Decision No. 134 of 2025.
Practice note:
Document collection under REAR is a separate obligation from CDD under the MoET DNFBP Guidelines. REAR requires collection and recording of specific identity and transaction documents at the point of a qualifying payment. This does not substitute for the full CDD and EDD obligations that apply to the broader client relationship under the AML/CFT regulatory framework.
Understanding the Five Possible Results
Every assessment through the REAR Submission Obligation Checker produces one of five possible results, each with a clear explanation, regulatory references, and next steps:
| Result | Condition | Next Action |
|---|---|---|
| REAR Filing Required | Cash threshold met, OR virtual asset payment, OR converted VA payment recorded for freehold transaction by a covered entity in a qualifying role | Collect documents, complete REAR via UAE FIU goAML portal, retain records for 5 years |
| REAR Not Required (at this time) | Cash below AED 55,000, no VA payments, but transaction still in scope | Monitor future payments; re-assess if cumulative cash reaches AED 55,000 or VA payment is received |
| REAR Does Not Apply (sector) | Entity is not a real estate broker or legal professional covered by either circular | General AML/CFT obligations still apply under Federal Decree-Law No. 10 of 2025 |
| REAR Does Not Apply (not freehold) | Transaction is not a freehold property purchase or sale | REAR not triggered; other obligations (CDD, STR, SAR) still apply |
| Not Required, Out of Scope Role | Legal professional in advisory/litigation role only, OR broker in non-transaction engagement | Re-assess if engagement scope changes to qualifying transaction role |
Every result, regardless of outcome, includes a reminder that other goAML reporting obligations (STR, SAR, FFR, PNMR, HRC, HRCA) remain in force under the applicable circular and federal AML/CFT legislation. These are parallel obligations that are not displaced by the REAR assessment.
About AMLUAE
The REAR Submission Obligation Checker was developed by AML UAE, a UAE-focused AML/CFT compliance consultancy serving DNFBPs, financial institutions, and regulated professionals across the UAE. AML UAE operates as part of NIYEAHMA Consultants LLP and is a core component of NIYEAHMA’s AMLVerse, a global AML compliance ecosystem designed to connect consulting, regulatory knowledge, professionals, implementation frameworks, and technology.
The tool’s regulatory accuracy has been developed and reviewed for:
- UAE DNFBP AML/CFT regulatory frameworks, including MoET, MoJ, DFSA, FSRA/ADGM, VARA, and CMA supervision
- goAML reporting obligations, including STR, SAR, FFR, PNMR, REAR, and DPMSR submissions
- FATF recommendations and the UAE mutual evaluation follow-up compliance
- Enterprise-Wide Risk Assessment (EWRA) design and implementation
- AML/CFT policy and procedure development for regulated entities
AMLUAE’s suite of free interactive compliance tools, including the goAML Registration Obligation Checker, UAE AML Supervisory Authority Finder, Individual KYC and Corporate KYC Wizards, Adverse Media Search Tool, and Onsite Inspection Readiness Toolkit, reflects a commitment to making high-quality, practical AML/CFT compliance resources accessible to all regulated entities in the UAE.
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Frequently Asked Questions - DPMSR Filing in UAE
What is a REAR and who must file it?
A Real Estate Activity Report (REAR) is a regulatory report submitted via the UAE FIU goAML portal. It must be filed by real estate brokers and agents under MoET Circular No. 05/2022, and by lawyers and law firms under MoJ Circular No. 14 of 2022, when qualifying payment conditions are met on a freehold property purchase or sale transaction.
What triggers a REAR filing obligation?
Three conditions trigger REAR: (1) cash payments totalling AED 55,000 or more for the whole or part of the property value; (2) any payment made in virtual assets; or (3) funds used in the transaction that were converted from virtual assets. “Other” payment modes such as cheques or bank transfers do not trigger REAR independently.
Does REAR apply to leasehold or rental transactions?
No. Both circulars are anchored exclusively to freehold property purchase and sale transactions. Leasehold, tenancy, rental, and property management activities fall outside the REAR filing scenarios in the circulars.
Does filing a REAR exempt me from other goAML reports?
No. For real estate brokers and agents, MoET Circular No. 05/2022, Clause 7, explicitly states that REAR submission does not exempt the obligation to file STR, SAR, FFR, PNMR, High Risk Country Transaction Report (HRC), or HRCA when conditions are met. For legal professionals, this obligation arises from Federal Decree-Law No. 10 of 2025 and Cabinet Resolution No. 134 of 2025.
Does REAR apply to lawyers who only provide legal advice?
The REAR filing scenarios in MoJ Circular No. 14 of 2022 are intended for legal professionals who are preparing, conducting or executing a financial transaction for a qualifying freehold purchase or sale. Where the engagement appears limited to legal advice, legal opinion, or dispute representation, the obligation may not arise from that specific engagement, though independent confirmation is recommended where uncertainty exists.
What is the difference between MoET and MoJ REAR obligations?
Both circulars share the same payment triggers and thresholds. The key difference is the regulated entity: MoET Circular No. 05/2022 covers real estate brokers and agents; MoJ Circular No. 14 of 2022 covers lawyers and law firms. Each profession’s ongoing reporting obligations also differ slightly in their source authority.
What documents must be collected and retained alongside the REAR?
For individual buyers and sellers: valid Emirates ID or valid passport copy, receipts, invoices, and the Sale and Purchase Agreement. For corporate buyers and sellers, additionally: Trade Licence, Articles / constitutional documents, UBO Register, and Emirates ID or valid passport copy for all Beneficial Owners and shareholders. All documents must be retained for a minimum of 5 years.
Does DPMSR apply to free zone UAE companies?
Yes. The obligation applies to all UAE-licensed DPMS dealers, including those in free zones such as DMCC, DAFZA, and others. The tool covers all free zone wire scenarios from goAML FAQs v1.9, Q.53 Rows 16.a to 16.f.
What happens if cash payments are made in instalments below AED 55,000 each?
REAR assesses cumulative cash payments on a transaction. If multiple cash payments together equal or exceed AED 55,000 for the whole or part of the property value, the filing obligation arises regardless of individual payment amounts. The tool records each instalment separately to detect potential structuring.
What is the difference between DPMSR and STR?
A DPMSR is threshold-based, and it is filed automatically when qualifying conditions are met, regardless of suspicion. An STR is suspicion-based, and it is filed whenever there are reasonable grounds to suspect money laundering or terrorist financing, regardless of amount or payment mode. They serve different purposes and can both be required for the same transaction.
Is the REAR Submission Obligation Checker a legal advice tool?
No. The REAR Submission Obligation Checker is a first-level compliance screening tool based on the current UAE AML/CFT framework and the REAR filing scenarios reflected in MoET Circular No. 05/2022 and MoJ Circular No. 14 of 2022. It does not constitute legal or regulatory advice. Users should obtain independent professional confirmation for complex or uncertain cases.
Where do I file the actual REAR?
REAR is filed via the UAE FIU goAML portal, the dedicated platform for all goAML report submissions in the UAE. Access is through the UAE FIU’s online portal.
Is this tool free to use?
Yes. The REAR Submission Obligation Checker is a free interactive tool published by AML UAE on amluae.com as part of its commitment to accessible AML/CFT compliance resources for UAE DNFBPs and regulated professionals.
Disclaimer
This guide is provided for general information and educational purposes only. It does not constitute legal or regulatory advice. Regulatory requirements may change; always verify obligations against the latest official circulars, Cabinet Resolutions, and Federal Decree-Laws. AMLUAE and NIYEAHMA Consultants LLP accept no liability for reliance on this guide without obtaining independent professional advice.
Contact: info@amluae.com | amluae.com/contact-aml-uae/
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