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UAE AML POLICY
For Real Estate Brokerage Companies & Real Estate Agents

1. Purpose

The purpose of this policy is to:

Prevent money laundering (ML), terrorist financing (TF), and proliferation financing (PF).
Ensure compliance with UAE AML/CFT laws.
Protect the company, its employees, and clients from financial crime.
Establish procedures for customer due diligence and reporting suspicious activities.

2. Scope

This policy applies to:

Directors
General Manager
Compliance Officer / MLRO
Brokers
Sales & Leasing Agents
Property Consultants
Marketing Staff
Administration
Finance Department
Third-party representatives

3. Applicable UAE Laws

The company shall comply with:

Federal Decree Law No. 20 of 2018 (and subsequent amendments)
Cabinet Decision No. 10 of 2019 (and subsequent amendments)
Ministry of Economy & Tourism AML Guidelines for Real Estate Agents and Brokers
UAE Financial Intelligence Unit (FIU) requirements
goAML reporting requirements
Executive Office for Control and Non-Proliferation (Targeted Financial Sanctions) requirements.

4. AML Compliance Officer (MLRO)

The company shall appoint an AML Compliance Officer responsible for:

AML implementation
Customer risk assessment
STR/SAR submission
goAML administration
Staff training
Record keeping
Regulatory inspections
Internal AML audits

5. Risk-Based Approach (RBA)

Every client shall be assigned a risk rating.

Low Risk

UAE resident
Salary income
Local bank financing
Individual buyer

Medium Risk

Foreign investor
Corporate buyer
Multiple property purchases

High Risk

Cash transactions
Politically Exposed Persons (PEPs)
Complex ownership structures
Offshore companies
Virtual asset payments
High-risk jurisdictions
Unusual payment structures

Enhanced Due Diligence (EDD) must be applied to high-risk customers.

6. Customer Due Diligence (CDD)

Before accepting any client, the company shall obtain:

Individual

Emirates ID
Passport
Visa copy (where applicable)
Address
Contact information
Occupation
Employer
Source of Funds
Source of Wealth

Company

Trade License
MOA/AOA
Certificate of Incorporation
Shareholder Register
UBO (Ultimate Beneficial Owner)
Authorized Signatory
Board Resolution (where applicable)

7. Know Your Customer (KYC)

Agents must verify:

Identity
Beneficial ownership
Purpose of transaction
Occupation
Source of funds
Expected transaction value
Payment method

No transaction shall proceed without satisfactory KYC.

8. Source of Funds Verification

The company shall verify:

Salary certificates
Bank statements
Business income
Property sale proceeds
Inheritance
Investment income
Company financials

Large cash transactions require enhanced scrutiny.

9. Sanctions Screening

All customers shall be screened against:

UAE Local Terrorist List
UN Sanctions List
Internal watchlists

Screening must occur:

Before onboarding
Before closing
During ongoing relationships

10. Politically Exposed Persons (PEPs)

For PEPs:

Senior management approval
Enhanced Due Diligence
Source of Wealth verification
Continuous monitoring

11. Suspicious Transaction Indicators

Employees must report if they observe:

Refusal to provide identification
False documents
Third-party payments without explanation
Unusual cash payments
Frequent changes of purchaser
Immediate resale without commercial reason
Complex ownership structures
Overpayment
Underpayment
Funds from unrelated countries
Cryptocurrency without explanation
Reluctance to disclose beneficial owner

12. Reporting Obligations

The MLRO shall submit reports through goAML where required.

Reports may include:

Suspicious Transaction Reports (STR)
Suspicious Activity Reports (SAR)
Real Estate Activity Reports (REAR), where applicable under current UAE requirements.

Employees must never inform customers that a report has been filed (no "tipping off").

13. Cash Transactions

The company shall:

Record all cash payments.
Verify the source of cash.
Apply enhanced checks for large cash transactions.
Comply with UAE reporting obligations for qualifying transactions.

14. Record Keeping

Maintain for at least five years:

KYC records
Contracts
Form F
Passport copies
Emirates IDs
Bank statements
Source of Funds documents
Payment receipts
STR/SAR records
Risk assessments
Internal investigations
Training records.

15. Employee Responsibilities

Every employee shall:

Complete AML training.
Follow KYC procedures.
Report suspicious activities.
Maintain confidentiality.
Avoid facilitating illegal transactions.

16. Training

AML training shall be conducted:

Upon joining
Annually
Whenever regulations change

Training topics include:

AML laws
Red flags
Customer Due Diligence
goAML
Sanctions
PEP identification
Record keeping

17. Internal Audit

The company shall periodically review:

AML controls
Client files
KYC documentation
High-risk transactions
Employee compliance
Reporting procedures

18. Confidentiality

AML reports are confidential.

Employees shall not disclose:

STR submissions
Internal investigations
Compliance reviews
Regulatory inquiries

19. Penalties

Failure to comply may result in:

Disciplinary action
Employment termination
Regulatory penalties
Civil liability
Criminal prosecution where applicable

20. Agent AML Checklist

Every real estate agent should complete the following before concluding a transaction:

☐ Verify Emirates ID / Passport
☐ Complete KYC form
☐ Verify Source of Funds
☐ Screen customer against sanctions lists
☐ Check PEP status
☐ Identify the Ultimate Beneficial Owner (for companies)
☐ Complete customer risk assessment
☐ Escalate suspicious matters to the MLRO
☐ Ensure all documents are filed
☐ Do not tip off the client if a report is being considered

Downtown Dubai

In the heart of the Dubai - United Arab Emirates, a district rises that has come to define modern urban ambition. Downtown Dubai, master-planned by Emaar Properties, is not merely a neighborhood; it is a carefully curated ecosystem that flawlessly integrates high-end living, world-class leisure, and global commerce. Anchored by the iconic Burj Khalifa, this is where the city's dynamic spirit truly comes to life.

A Hub for Luxury Living

Living in Downtown Dubai means waking up to a skyline dominated by the world's tallest building. The area offers an impressive range of residential options, from sleek high-rise apartments and spacious penthouses to exclusive branded residences. These homes, found in towers like the Burj Khalifa itself, The Residences, and Boulevard Point, often feature premium finishes and breathtaking views of the city or the Dubai Fountain.

This prime location comes at a premium, reflecting its status as a top choice for luxury living and a strong investment destination. As of 2025, average rental prices for a one-bedroom apartment sit at around 116,000 AED annually, while a two-bedroom apartment averages 181,500 AED. For those looking to buy, the investment is substantial, with a one-bedroom averaging 1.95 million AED and a two-bedroom commanding over 8.3 million AED.

The lifestyle here is one of convenience and prestige. Residents enjoy a "pedestrian-friendly" environment with wide boulevards and landscaped spaces. Everything from gourmet supermarkets like Spinneys and Waitrose to boutique fitness studios and tranquil parks like Burj Park are within walking distance. However, this central convenience comes with a recognized drawback: heavy traffic during peak hours is a common challenge for this bustling district.

A World of Leisure and Entertainment

Downtown Dubai is a global entertainment destination. The Dubai Mall, one of the world's largest shopping centers, anchors the retail experience with over 1,200 stores, ranging from high-end fashion at Fashion Avenue to the vibrant new Chinatown Dubai. But it's more than just shopping; it's an entertainment hub featuring the Dubai Aquarium & Underwater Zoo, an Olympic-sized ice rink, and KidZania.

The cultural soul of the district is the Dubai Opera, a stunning dhow-shaped venue hosting world-class performances, and the traditional charm of Souk Al Bahar offers a taste of Arabian market culture with a modern twist. Of course, no visit is complete without witnessing the choreographed spectacle of the Dubai Fountain, or ascending the Burj Khalifa for an unforgettable panoramic view. The district's appeal is set to grow with projects like the 445-meter-high Downtown Residences, a future architectural icon designed to redefine vertical urban living with luxury amenities like AI yoga pods and sky gardens.

A Thriving Commercial Core

Beyond its residential and leisure appeal, Downtown Dubai is a significant commercial powerhouse. Emaar Square, a six-tower complex within the district, stands as the premier business address, providing over 1,000,000 square feet of office space. This hub is home to prestigious financial and consulting firms like HSBC, PwC, and Deloitte.

Strategically located along Sheikh Zayed Road (E11) and Financial Centre Road (D71), the area offers immediate connectivity to key business hubs like the Dubai International Financial Centre (DIFC) and Business Bay, making it an ideal base for professionals and corporations alike. Its unparalleled transport links, including the Burj Khalifa/Dubai Mall Metro Station, ensure seamless access to the rest of the city.

The Centre of Now

From the architectural marvels of its skyline to the sophisticated energy of its streets, Downtown Dubai truly lives up to its billing as "The Centre of Now". It is a district that offers an unparalleled blend of high-octane commerce, luxurious living, and world-class leisure, creating a unique and vibrant urban experience at the heart of the city.

Asif Memon

Business Bay, Dubai

1. Overview

Business Bay is one of Dubai's largest mixed-use central business districts, located along the Dubai Water Canal, roughly 1.5 km from Burj Khalifa and Downtown Dubai, with direct access to Sheikh Zayed Road and Al Khail Road. It was conceived as a "Manhattan of the Middle East" — a dense corridor of residential towers, offices, hotels, and retail built around a canal waterfront.

Launched: 2003, as part of H.H. Sheikh Mohammed bin Rashid Al Maktoum's vision to create a new commercial heart of Dubai.
Master developer: Dubai Properties Group (part of Dubai Holding), which handled master planning and infrastructure, while individual plots were sold/leased to dozens of private developers who built their own towers.
Total area: Approximately 46 million sq ft (about 8 sq km).
Planned capacity: Designed to eventually house 135,000–191,000+ residents and workers, plus tens of millions of annual visitors, depending on which planning-stage estimate is cited.
Land-use mix (master plan): Roughly 22% residential, 18.5% commercial, and the remainder (~59%) mixed-use towers combining residential, office, hotel, and retail components in a single building.

2. History and Development Timeline

2003–2008 (Phase 1): Infrastructure phase — reclaiming marshy/low-lying land bordering Dubai Creek, laying roads, utilities, and the canal extension. Core infrastructure was largely complete by 2008.
2008–2015 (Phase 2): High-rise construction phase. This period coincided with the 2008–09 global financial crisis, which stalled or delayed numerous towers across Dubai, including many in Business Bay — pushing the original 2015 full-completion target out by a decade or more.
2015–present (Phase 3): Continued build-out, including luxury and branded-residence towers, hotel openings, and completion of previously stalled projects. Business Bay is still an active construction zone today, alongside Dubai Canal-front expansion.

First buildings constructed

The first towers to be completed in Business Bay were the Executive Towers, a 12-tower complex developed by Dubai Properties, with construction starting in 2007 and opening in 2010. The complex includes 10 residential towers, one commercial tower (Aspect Tower), and one hotel tower (Taj Dubai, formerly The Taj Hotel), all connected by a shared three-storey podium. These towers sit near the main entrance to Business Bay and are widely credited as the district's first completed buildings.

Shortly after, One Business Bay (ONE by OMNIYAT) — a 35-storey office skyscraper at the northern Sheikh Zayed Road entrance — was developed by Omniyat, with construction starting in 2006 and completing in 2011.

3. Key Developers

Business Bay was master-planned by Dubai Properties Group, but built out by a large number of independent developers who purchased or were allocated individual plots. Notable developers with towers in Business Bay include:

Dubai Properties — master developer; Executive Towers, Bay Square, and other residential/mixed clusters
Omniyat — One Business Bay, The Opus, and various luxury towers
Damac Properties — multiple residential and branded towers (e.g., Damac Maison Aykon City)
Select Group — several residential and mixed-use towers (e.g., The Edge, Peninsula)
Binghatti — Burj Binghatti Jacob & Co. and other towers
SAAS Properties / Richreit Real Estate — SAAS Business Bay
The First Group — The First Collection Business Bay (hotel)
Marriott/regional partners — St. Regis Downtown Dubai (formerly Renaissance Downtown Hotel)
Numerous smaller/mid-size local developers behind individual towers such as Silver Tower, The Prism, The Pad, Prime Tower, and Santeville

Because Business Bay is a freehold zone with plots sold to multiple parties, there is no single master builder for the vertical towers — Dubai Properties set the master plan and infrastructure, while each tower was designed, financed, and built independently.

4. Number of Buildings

Estimates vary slightly by source and by what is counted (residential/commercial only vs. all structures):

~240 total planned/registered building plots across the district (commercial, hotel, office, and residential).
~361 registered building developments tracked across various stages, per Dubai property-research platforms (this broader figure includes cancelled, on-hold, and re-launched projects historically associated with plots in the area).
Of the actively tracked residential/commercial buildings: ~174–179 completed buildings ~65–66 buildings currently under construction at various stages

These figures shift over time as stalled 2008-crisis-era projects are revived, cancelled, or replaced by new towers (e.g., a plot originally allocated to "Hydra Towers" was later redeveloped as SAAS Business Bay).

5. Hotels

Business Bay has grown into a major hospitality cluster, with roughly 25–30 branded hotels physically located within the district (aggregator sites listing "hundreds" or "thousands" of hotels are typically counting the broader Dubai/Downtown area within a few kilometers' radius, not Business Bay itself). Notable hotels actually within Business Bay include:

Taj Dubai (in Executive Towers)
St. Regis Downtown Dubai (formerly Renaissance Downtown Hotel)
The First Collection Business Bay
DoubleTree by Hilton Dubai – Business Bay
V Hotel Dubai, Curio Collection by Hilton
Radisson Blu Hotel, Dubai Waterfront
Hotel Indigo Dubai Downtown (IHG)
Citymax Hotel Business Bay
Grand Mercure Business Bay
Embassy Suites by Hilton Dubai Business Bay
InterContinental Residences Dubai Business Bay

Hotel occupancy in Dubai overall runs among the highest globally, and Business Bay/Downtown-adjacent hotels benefit directly from proximity to Burj Khalifa, Dubai Mall, and the Dubai Canal — though granular hotel-only occupancy specific to Business Bay isn't separately published; it tracks closely with Dubai's citywide average (historically 75–85%+ year-round, with peak-season rates higher).

6. Occupancy Snapshot (2025–2026 data)

Residential

Vacancy rate: below 6% (Q1 2026) — meaning roughly 94% occupancy across residential units in Business Bay.
Business Bay posted the sharpest year-on-year rent increase of any Dubai submarket in Q4 2025 (+18.2% YoY), reflecting extremely tight supply relative to demand.
Broader investment guides describe Business Bay residential occupancy as "85%+ year-round," consistent with the tighter Q1 2026 vacancy figures.
Short-term/holiday-let (Airbnb-style) occupancy in Business Bay is separately reported at roughly 43–44% average, which is a distinct market from long-term residential leasing.

Office / Commercial

Dubai's citywide office occupancy stood at roughly 92% overall in 2025, with Grade A stock at ~95% occupancy and Grade B/C averaging ~90%.
Business Bay, alongside DIFC and Downtown Dubai, is cited among the districts with the highest office occupancy in the city — commonly quoted at 95–97%, and office vacancy below 10% (some reports cite ~8.6% citywide vacancy in prime submarkets).
New Grade A towers in Business Bay with modern, ESG-compliant space are reported to be at effectively full occupancy, with strong pre-leasing on new supply.
Office rents in Business Bay averaged AED 151/sq ft in early 2026, above the Dubai-wide average of AED 117/sq ft, and have risen as much as 44% YoY in some reports — a further sign of demand outstripping supply.

Hotels

Dubai's hotel sector overall maintains occupancy rates among the highest of any global city; Business Bay's hotels, given their proximity to Downtown/Burj Khalifa, generally track at or above the citywide average rather than lagging it, though a district-specific occupancy figure for hotels alone isn't independently published by major research firms.

7. Summary

Master developer Dubai Properties Group (Dubai Holding)

First completed buildings: Executive Towers (2007 start, 2010 completion) Total area~46 million sq ft

Total buildings (all stages)~240–361 (source-dependent)

Completed buildings~174–179

Under construction~65–66

Hotels in the district~25–30 branded properties

Residential occupancy~85–94% (vacancy <6% in Q1 2026)

Office occupancy~92–97% (among Dubai's highest)

Notes on data reliability

Business Bay figures — especially total building counts and occupancy percentages — vary across sources depending on methodology, what counts as "the district" boundary, and how frequently the data is refreshed. The figures above are drawn from Dubai property-research platforms (Propsearch), commercial real estate reports (Cushman & Wakefield, Savills-sourced commentary), and RERA/DLD-referenced rental market reports current as of late 2025–early 2026. For investment or transactional decisions, verify current numbers directly with the Dubai Land Department (DLD) or a licensed real estate research firm, as this is a fast-moving market.