REAR and goAML filings: how a brokerage tracks cash and crypto payments across a deal

What a REAR is and why it exists

The Ministry of Economy's Circular 5/2022 (dated 24 June 2022, effective 1 July 2022) tells licensed real estate brokers and agents what to do on freehold property deals that involve cash or virtual assets. The Ministry's news release of 7 July 2022 says the rules apply to licensed brokers and agents including those in free trade zones. The report is a threshold report: you file it whether or not you suspect anything. The 2026 Supplemental Guidance for real estate agents and brokers says the same: the duty is not risk-dependent, applies even when due diligence is satisfactory and there are no red flags, and applies whether the transaction completes, is attempted or is discontinued.

Two notes on the source, because loose claims circulate. REAR is a Ministry of Economy instrument, not a DLD rule. And the circular's original legal basis, Cabinet Decision 10 of 2019, has since been replaced. The current framework is Federal Decree-Law 10 of 2025 and Cabinet Resolution 134 of 2025, so check the Ministry's AML page for the current instruments.

When a deal crosses the line: the three triggers in plain words

For the purchase and sale of freehold real estate, the circular covers:

1. Cash. Any single physical cash transaction, or several transactions, equal to or above AED 55,000, for the whole property value or a part of it. The 2026 guidance phrases it as AED 55,000 or more of cash "in a single payment or multiple payments".
2. Virtual assets. A deal where part or all of the payment is made in virtual assets (crypto).
3. Conversion. A deal where funds were converted from or to a virtual asset to cash, for part or all of the value.

What is not an official trigger: "offshore buyers". You will see that in some consultancy pages. It is in no official text I read.

The hard part: cash that arrives in pieces

Real deals do not produce one tidy payment. A buyer hands some cash to an agent, some to a developer's sales office, some at the trustee office. You may never see all of them. Meanwhile the circular counts several transactions together. So a tracker built per receipt will miss deals. It has to add up cash per property, per party.

Two unresolved points. First, the circular says "physical cash". Cheques are not named, and neither is any treatment of bank transfers or manager's cheques. Do not assume a cheque is outside the rule. Ask the Unit at goaml@uaefiu.gov.ae for goAML questions, or the Ministry's supervision team at AMLsupervision@economy.ae (the circular's own contact addresses). Second, whether a further report is needed when more cash arrives after you have filed: I found no official guidance, so ask.

Off-plan sales and rentals: the circular says freehold purchase and sale "according to the description and determination of the law of each emirate". Off-plan freehold sales are likely in scope but that is not stated in so many words. Leases are not mentioned. Confirm with the Ministry.

A per-deal payment log that adds up cash for you

Build one table, in a sheet or in your CRM (the system where you keep clients and deals), with a row for each payment received on a deal:

Column	What it holds
Date	The day the payment was made or seen
Payer name	Who actually paid
Payer matches buyer?	Yes or no; a no is a red flag to escalate
Method	Cash, cheque, bank transfer, virtual asset
Amount (AED)	The amount
Receipt number	Link to the scanned receipt
Running cash total	Formula: sum of cash and virtual-asset rows for this deal
REAR status	Not triggered, triggered, filed (with reference)

Worked example (made-up numbers). A buyer pays AED 20,000 in cash on Monday, AED 20,000 on Wednesday and AED 20,000 on Friday. No single payment is near the line, but the running total is AED 60,000, so the REAR is triggered. If the same AED 60,000 had arrived by bank transfer from the buyer's own account, it would not be a cash trigger on the circular's wording, though a payment from a third party's account would still be a red flag worth escalating.

Add two warning levels so nobody is surprised: highlight the row when the cash total reaches 50 percent of the threshold, and again at 80 percent, so the compliance officer expects a filing. And make the CRM refuse to move the deal to "closed" until the REAR status field is filled in. These are my internal-control suggestions, not rules.

Who files, who collects, and who signs off inside the brokerage

The circular addresses "brokers and agents". The Ministry's DNFBP Guidelines (March 2026) list filing all applicable reports, including REARs, among the compliance officer's duties, and require the compliance officer to be the registered goAML user. So in practice: the brokerage, normally through its compliance officer, files. Agents collect and record. A workable rule: any cash or virtual-asset receipt is entered in the log the same day, by the agent, with the receipt attached. The compliance officer reviews the log.

Some brokerages decide not to accept cash at all, which removes most of the issue. That is an owner's policy choice. It does not remove the duty if cash reaches the buyer-developer side and you record it, so keep the log anyway.

Registration comes first. The Ministry's goAML registration page asks for an authorisation letter, passport, visa and Emirates ID copies, the trade licence and the Google Authenticator app, and gives a call centre number of 800-1222. A brokerage that has never filed still needs an active registration.

What to record and keep, and for how long

Circular 5/2022 asks you to obtain and record ID (Emirates ID or passport copy for individuals; for companies the trade licence, articles, register of beneficial owners, and IDs of all beneficial owners and shareholders or partners), and to record receipts, invoices, contracts and the Purchase and Sale Agreement. Keep the records for not less than five years. Under the wider UAE anti-money-laundering rules, that five years runs from the latest of the end of the client relationship, the completed transaction, an inspection, an investigation or a final court judgment, and covers business correspondence and customer communications. The source is the federal AML framework (Cabinet Resolution 134 of 2025, Art. 25; MoET DNFBP Guidelines, section 11), not a DLD chat rule, and WhatsApp is not named, so client messages tied to a deal are likely to count as business correspondence, which is an interpretation. Confirm with a lawyer. Tools for the identity-checking side are compared in AML and KYC software for UAE brokers.

The deal file also doubles as REAR evidence, see the Dubai deal file checklist.

How software and AI help with REAR tracking, and what stays human

The Ministry's 2026 guidance says REAR reporting should be built into operational workflows: transaction processing, payment acceptance and deal completion, with accurate records of values, payment methods, parties and timelines, and clear allocation of responsibility between the business and the compliance officer. That is a software brief. Concrete tasks:

• Running totals. A formula or CRM field that adds up cash and virtual-asset payments per deal and flags 50 percent, 80 percent and 100 percent of the threshold.
• Receipt capture. AI can read a photographed receipt or a bank slip and fill in date, amount and payer name for a person to confirm.
• Structuring alerts. A report of deals with several payments just under a level in a short time, or payments by someone other than the buyer.
• Draft fields. Pre-fill the data that goes into the goAML form from the log and the deal file, so the compliance officer checks rather than retypes.
• Month-end summary. A list of deals with cash, their status and missing receipts.

What stays human: deciding whether a pattern is suspicious, filing in goAML, and deciding what to do about a payment you did not expect. I build payment logs and dashboards like this for brokerages, but a well-built sheet does the first job.

Try it yourself with Claude (an AI assistant). Paste a made-up payment log (dates, payers, methods, amounts) and ask: "Add a running cash total, tell me on which payment the total crosses AED 55,000, and list any payment made by someone other than the buyer." Check the arithmetic yourself. Use invented data, not real clients.

REAR is not an STR: when a split-payment pattern becomes a suspicion

A STR (suspicious transaction report) is filed when you suspect money laundering, whatever the amount. Circular 5/2022 says a REAR does not exempt you from the Ministry's other report types (STR, SAR, FFR, PNMR, HRC and HRCA). The 2026 guidance adds that if a transaction exceeds the REAR threshold and there is also suspicion, both must be met.

The official red flags include payments intentionally divided into smaller amounts at short intervals, possibly to avoid detection, and payments from accounts not held in the buyer's name. So a buyer who pays AED 54,000 cash, then another AED 54,000 two days later is not "safe because each payment is under the line". It is a pattern for the compliance officer. Agents must not tell the client they are suspicious. Escalate and stop.

What the rules do not say, and how to ask the regulator

• Filing deadline. I found none in the circular, the Ministry's 2022 release or the 2026 guidance, which mentions "predefined parameters and timelines" without stating them. An unofficial two-week figure comes from a consultancy and is borrowed from another sector. My suggestion as an internal rule: file on the day the threshold is crossed.
• Cheques and transfers. The wording is "physical cash". Ask.
• Updated reports. Ask.

Write the question in an email, keep the reply in the compliance file, and date it. That is also useful evidence if you are inspected.

On penalties: the published schedule under Cabinet Resolution 71 of 2024 lists AED 50,000 to 200,000 for failing to keep records or make them available, AED 50,000 to 200,000 for failing to register on the Unit's goAML system, and AED 100,000 to 500,000 for failing to report suspicious transactions promptly or provide information the Unit asks for, with a possible doubling on repeat. I found no line item for REAR as such. Newer instruments replaced the laws the resolution cites and I could not confirm whether the schedule still operates unchanged, so confirm the current schedule with the Ministry of Economy.

A simple month-end REAR review routine

1. Export every deal that closed or stalled this month.
2. For each, confirm the payment log exists and the REAR status is set.
3. Check that every cash or virtual-asset row has a receipt attached.
4. List deals with cash above 50 percent of the threshold and confirm filing is done or planned.
5. List deals where the payer is not the buyer and pass them to the compliance officer.
6. Save the review, dated and signed, in the compliance folder. See the annual AML review calendar.

Mistakes to avoid

• Tracking per receipt, not per deal.
• Confusing REAR with an STR, or thinking one replaces the other.
• Assuming cheques are outside the rule without asking.
• No goAML registration, or a registration nobody can log in to.
• Cash arriving at the developer side and never being logged by the broker.
• Missing attachments: receipts, IDs, the sale agreement.

How I'd approach this

First decide your cash policy, because it changes everything. Then make the payment log mandatory and put it in front of the person who closes the deal. Build the running total before anything fancy. Ask the Ministry the three open questions in writing and keep the answers. If you are unsure about a specific deal, ask your compliance officer or a lawyer before the deal closes, not after.