Real estate brokers and dealers in precious metals and stones (DPMS) were the two most-penalised DNFBP sectors in the Ministry of Economy and Tourism's first-half 2025 inspection results. Of 1,063 violations and more than AED 42 million in fines, DPMS accounted for 473 violations and AED 20 million, and real estate brokers for 495 violations and AED 18.5 million. Weak suspicious transaction reporting was among the main findings.
Much of that comes down to one confusion: which report, when? This guide sets it out.
First, register
Every DNFBP supervised by the Ministry must be registered on goAML, the UAE FIU's reporting platform. Registration is done through the Compliance Officer, and the Ministry approves it. Failing to register carries a fine of AED 50,000 to AED 200,000 under Cabinet Resolution No. 71 of 2024. In 2023, the Ministry suspended 50 DNFBPs for three months for not registering.
Registration is not a one-off task. Keep user access current when your Compliance Officer or alternate changes.
Two kinds of report
It helps to split goAML reports into two families.
Suspicion-based reports are triggered by what you know or suspect. There is no value threshold.
Threshold-based reports are triggered by the type and size of a transaction. No suspicion is needed. You file because the rule says so.
A threshold report never discharges a suspicion report. If a AED 400,000 cash property purchase is also suspicious, you file a REAR and an STR.
Suspicion-based reports
STR: Suspicious Transaction Report
Filed where you suspect, or have reasonable grounds to suspect, that a transaction involves the proceeds of crime or is linked to money laundering, terrorist financing or proliferation financing. Under Federal Decree-Law No. 10 of 2025, you must report without delay and regardless of value.
SAR: Suspicious Activity Report
Filed for suspicious activity or behaviour that does not involve a completed transaction. A buyer who walks away when asked for source-of-funds documents, or a customer who tries to split a gold purchase to stay under a threshold, may warrant a SAR.
AIF and AIFT: Additional Information File
Used to add information to an STR or SAR you have already filed, citing the original report number, or to respond to an FIU request.
HRC and HRCA: High-Risk Country reports
Used for transactions or activity involving high-risk jurisdictions identified by the National Committee. Follow any FIU instructions on whether the transaction may proceed. Check the current country list: Ministry Circular No. 2 of 2026 replaced it on 14 September 2026.
Threshold-based reports
REAR: Real Estate Activity Report
Ministry Circular No. 05/2022, effective 1 July 2022, requires real estate brokers and agents to file a REAR for the purchase or sale of freehold property where:
- the payment, or part of it, is made in cash of AED 55,000 or more, in a single payment or several;
- any part of the payment is made in virtual assets; or
- the funds used were derived from virtual assets.
You must also keep copies of the parties' identification documents for five years.
DPMSR: Dealers in Precious Metals and Stones Report
Ministry Circular No. 08/AML/2021, effective 12 June 2021, requires DPMS to file a DPMSR for:
- cash transactions of AED 55,000 or more with individuals, resident or non-resident; and
- transactions of AED 55,000 or more with entities, whether in cash or by wire transfer.
Dealers must collect identification from individuals and trade licence details from entities, and keep records for five years. The Ministry's 2026 supplemental guidance for DPMS confirms these triggers.
Sanctions reports: CNMR and PNMR
Where a customer or counterparty matches a name on the UAE Local Terrorist List or the UN Consolidated List, you must freeze without delay (within 24 hours of the listing decision) and report through goAML within five business days. A confirmed match is reported as a CNMR (formerly FFR). A partial match you cannot rule out is reported as a PNMR.
Matches against other lists, such as OFAC, EU or UK, do not go through CNMR or PNMR. If they raise suspicion, file an STR or SAR.
Mistakes we see most often
- Filing a REAR or DPMSR and assuming the suspicion question is answered.
- Missing the wire-transfer limb of the DPMSR for corporate buyers.
- Aggregation failures. Several cash payments towards one property count together.
- Treating crypto-funded property deals as ordinary transactions.
- Tipping off the customer by asking questions that signal a report is coming.
- No written rationale where the Compliance Officer decides not to file an STR.
- Batching threshold reports monthly instead of filing each one promptly.
The Ministry's 2026 guidance for brokers refers to "predefined parameters and timelines" for REARs. Set a short internal deadline for every threshold report and track it.
The cost of getting it wrong
Under Cabinet Resolution No. 71 of 2024, failing to report a suspicious transaction promptly carries a fine of AED 100,000 to AED 500,000, and tipping off carries the same range. Failing to report a partial name match can cost AED 50,000 to AED 1,000,000. Fines can double for repeat violations. Separately, deliberately or grossly negligently failing to file an STR is a criminal offence under Federal Decree-Law No. 10 of 2025, punishable by imprisonment and/or a fine of AED 100,000 to AED 1 million.
A good goAML record shows more than reports filed. It shows a decision, with reasons, on every alert.