Rashid is brokering the sale of a freehold apartment in Dubai Marina. The buyer pays a AED 60,000 deposit in banknotes and the AED 1,140,000 balance by bank transfer, and nothing about him seems suspicious. What must the brokerage file?
Ministry of Economy Circular No. 05/2022 requires a Real Estate Activity Report (REAR) on goAML when a freehold sale or purchase involves cash payment(s) of AED 55,000 or more (as at 12 Oct 2026). The AED 60,000 cash deposit meets that trigger even though most of the price came by transfer. A REAR is a threshold report, not a suspicion report, so an STR is needed only if something is actually suspicious. RERA is not the AML reporting channel: reports go to the UAE Financial Intelligence Unit through goAML. Source: MoE Circular No. 05/2022 on the Real Estate Activity Report; goAML report types (as at 12 Oct 2026).
Treating the AED 55,000 cash rule as a suspicion test, or ignoring the cash part because most of the price was a bank transfer.
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