How to Submit a Real Estate Activity Report (REAR) in goAML UAE
What is a REAR report in goAML?
A Real Estate Activity Report (REAR) is a goAML report for specified property transactions handled by real estate brokers and agents. It differs from an STR or SAR: REAR reporting is tied to transaction criteria, while STR/SAR reporting concerns suspicion.
The UAEFIU report-type guidance describes REAR reporting for purchases or sales of freehold property where the payment includes cash of AED 55,000 or more, whether paid in one amount or multiple payments; where any part of the property value is paid in virtual assets; or where funds used for the transaction were converted to or from virtual assets. Check the latest UAEFIU guidance and your supervisory authority’s notices before applying these criteria to a live transaction, as reporting instructions can be updated.
Who should consider whether a REAR is required?
Brokers and agents should assess each transaction against the current REAR criteria. Record payment methods at onboarding and as payments arrive; a bank transfer does not remove the obligation where virtual assets or conversion to or from virtual assets are involved. Track split payments, and ensure staff handling booking documents and receipts escalate relevant information to the compliance officer or MLRO.
REAR versus STR and SAR
A transaction can meet a REAR criterion without being suspicious; a suspicious transaction may also fall outside REAR criteria. Assess the duties separately. UAEFIU FAQs state that both a REAR and an STR/SAR may be appropriate when a qualifying transaction is also suspicious. Filing one does not automatically meet the other obligation.
Information to prepare before filing
The exact fields and portal steps are set by the current goAML interface and official user guide. Before starting, assemble a complete transaction file so the compliance officer can provide accurate information and avoid unnecessary delays. Depending on the case, useful records may include:
- The property address, type, ownership or listing details, and transaction value
- The buyer, seller, beneficial-owner, and any relevant representative details
- The broker or agency details and the staff member handling the transaction
- The sale and purchase agreement or other transaction documents
- Payment dates, amounts, methods, and evidence of split cash payments
- Virtual asset details or evidence of conversion where relevant
- The source-of-funds information collected during customer due diligence
- A concise explanation of why the transaction meets the REAR reporting criteria
Use the information actually obtained and verified by the business. If a field cannot be completed, follow the current FIU instructions and record the steps taken to obtain it. Do not guess, invent, or enter placeholder information simply to complete a form.
A practical REAR filing workflow
1. Identify the trigger
At customer onboarding and each payment milestone, record how the transaction is being funded. Escalate cash payments, virtual-asset payments, and funds converted to or from virtual assets for review against the current REAR criteria. Track multiple payments so that separate cash amounts are not overlooked.
2. Confirm the reporting entity’s goAML access
The reporting entity should have active access to the FIU system, and its designated users and compliance officer details should be current. If access is inactive or a staff member has left, resolve access with the FIU process before a report is needed. Do not share login credentials among staff.
3. Review the transaction record
Check that names, dates, property details, amounts, and payment methods agree across the agreement, receipts, customer records, and internal notes. A second-person review can help catch missing payment stages or inconsistent spellings.
4. Select the correct report type
Use the current goAML report menu and FIU guide to select REAR. Do not submit a REAR as an STR merely because the transaction involved cash or virtual assets. If there is also a reasonable basis for suspicion, consider the separate STR/SAR process under the company’s procedures.
5. Submit, retain evidence, and monitor
Complete the required fields, attach or retain supporting documents as instructed, and submit through goAML. Save the submission reference, internal review notes, and evidence showing how the reporting decision was reached. If the FIU requests more information through the portal, assign responsibility and respond within the timeframe specified in that request.
Common REAR reporting mistakes
Common weaknesses include missing split payments, overlooking virtual-asset conversion, confusing REAR with an STR/SAR, inconsistent property data, and relying on outdated forms. A REAR also does not replace customer due diligence, source-of-funds checks, sanctions screening, or record keeping. Train property-facing staff to escalate relevant information promptly.
Build a repeatable process
Document who identifies a trigger, approves a report, retains evidence, and monitors portal messages. Review the procedure when FIU or supervisor guidance changes, and record the rationale for difficult reporting decisions.
A simple transaction log can help the firm track property reference, payment date, amount, payment method, reviewer, and reporting outcome. Restrict access to customer and report records, but make sure the MLRO can retrieve them for a supervisory review. Periodic sample checks can confirm that staff identify split payments consistently and that filed report references are saved with the transaction file. A manager can verify that the selected report type matches the payment facts and that any separate suspicion review is documented.
FAQs
Is a REAR the same as an STR?
No. A REAR is a report type for qualifying real estate activity. An STR or SAR is filed when the reporting entity has the required grounds for suspicion.
Does a cash payment below AED 55,000 always mean no REAR is required?
Not necessarily. The published guidance also considers multiple cash payments and virtual-asset payment or conversion scenarios. Review the full current criteria.
Should a broker file both a REAR and an STR?
Where a qualifying REAR transaction is also suspicious, the FIU’s reporting FAQs indicate that both reports may be appropriate. Assess each obligation separately.
Who normally prepares a REAR?
The reporting entity’s designated compliance officer or MLRO should oversee the filing, using transaction information supplied by relevant teams.
Where can I verify the current REAR process?
Use the latest UAEFIU report-type guidance, REAR user guide, FIU report FAQs, and any applicable supervisor notices.