When does a cash offer become a goAML report?
If a buyer has ever offered cash in a WhatsApp voice note and compliance heard about it at transfer, this is for you.
A buyer asks about a studio on Palm Jumeirah. Two messages later: "If I take it, can I pay part of the deposit in cash?" The agent says yes and books a viewing. Whether a report is now due depends on a number and a payment method. Nobody on the desk has looked at either.
The rule is in the Ministry of Economy's Circular 05/2022, dated 24 June 2022 and in force from 1 July 2022. On a freehold purchase or sale, a single physical cash transaction, or several together, equal to or exceeding AED 55,000 for the whole or part of the property value means the broker or agent must:
- record the buyer's and seller's ID documents (Emirates ID or passport);
- record the receipts, the contracts and the sale and purchase agreement;
- submit a Real Estate Activity Report (REAR) on the Financial Intelligence Unit's goAML platform.
The same steps apply when payment is in a virtual asset, or when the funds were converted from one. Records are kept for at least five years, and a REAR does not replace a suspicious transaction or suspicious activity report.
The Ministry's March 2026 Supplemental Guidance for Real Estate Agents and Brokers repeats the threshold as AED 55,000 or more in "a single payment or multiple payments". It adds two things. The duty "is not risk-dependent and must be fulfilled even when Customer Due Diligence measures have been satisfactorily completed and no red flags have been identified". And brokers "should ensure that REAR reporting is fully integrated into their operational workflows, including transaction processing, payment acceptance, and deal completion stages."
The guidance is guidance. It states that it "does not constitute additional legislation or regulation", and that the law prevails if the two differ. Your compliance officer or counsel confirms how it applies to your firm.
Who files it?
Your brokerage. The circular is addressed to licensed real estate brokers and agents, not to the buyer or the seller. Who inside the brokerage does the filing is for you to name. The guidance expects "clear allocation of responsibilities between business functions and the Compliance Officer", so the agent who hears the offer and the person who files should be two named roles with a handover between them.
Two points the documents leave to you:
- The deadline. Neither the circular nor the guidance gives a number of days. The guidance speaks of "predefined parameters and timelines" and sends brokers to the Ministry's guidelines for designated non-financial businesses. Ask your compliance officer or the Ministry for the deadline, and write it into your procedure as a number of days.
- The offer before the payment. The circular attaches the report to carrying out the cash transaction. It does not say what a broker does when cash is only offered. Our rule, not the Ministry's: treat the offer as the start of the file, because the ID, the receipt and the contract get recorded either way, and the person who files hears about it the same day, not at transfer.
One more case comes up on a desk. A buyer may pay cash straight to the seller or developer, and the broker never sees it. A practitioner reply on AML FAQs (October 2024) suggests a clause in the agreement with the seller or developer, requiring direct cash payments to be flagged to the broker. That is one practitioner's view, not a rule. Raise it with your compliance officer before the next off-plan launch.
Where does the offer first show up?
In a chat. The guidance lists "records keeping gaps" among the common challenges for brokers, and names three causes: "fragmented documents handling, the dependency of manual processes, and the reliance on informal communications channels". Without a structured system, it says, entities "may be unable to demonstrate their levels of compliance during inspections".
The circular lists what has to be recorded. Here is where each item can end up on a desk that runs on personal phones.
The guidance also lists red flags, and its customer-behaviour list includes one a desk hears: "The client is insisting on completing and paying for a high-value property in cash and has no clear source of funds." When suspicion arises, it says, the agent escalates internally and files a suspicious transaction or activity report "without tipping off the customer". That is why the note to compliance has to be one the buyer never sees.
What is the five-deal test?
A test you can run on your own desk this week. It is not a Ministry procedure. Take your last five freehold deals. For each one, find:
- how it was paid, in cash, transfer, cheque or virtual asset;
- where cash was first mentioned, if it was, and who wrote or said it;
- who in the brokerage heard it that day;
- where the receipt and the ID copy are, and who can open them.
A deal passes when you can open the payment method, the first mention of cash, the name of the person who heard it and the receipt in minutes, from the company's own records. If the answer for any deal is "a voice note on one agent's phone", your brokerage has a record problem before it has a filing problem. Fix the record first. For a deal that already closed with cash at or above the threshold, hand the file to your compliance officer today and ask whether a report is due and whether it is late.
Who owns each step?
One named person per step. A rule everyone follows "when they remember" has no owner. The decision rule we give a brokerage: any mention of cash, a deposit "in hand" or crypto, in any chat, is a trigger. The agent flags it the same day and the compliance officer decides what happens next.
A rule you can paste to the desk:
- If a buyer or seller mentions cash, a cash deposit or crypto in any chat, flag the lead the same day.
- Write a private note to the compliance officer with the amount and what was said.
- Collect the ID and the receipt before you take or reserve anything.
The compliance officer decides whether a report is due, replies on the note, and files on goAML. If one person is both your compliance officer and your top seller, name a second person who reads the flagged list, so the one who files is not the one who closed the deal. How that splits by desk size is your call:
- Under ten agents: whoever runs the desk reads the flagged list each morning, and the compliance officer works from it.
- Ten or more agents: the compliance officer sees every flag as it is raised, and the head of sales or the COO sees the weekly count.
- Any size: the flag, the note and the receipt live on the lead, so the file survives an agent leaving.
What does Mindcat Inbox record?
At Mindcat, we set up the lead panel in Mindcat Inbox with a cash flag for deals of AED 55,000 or more, a goaml-check label, and a private note that mentions your compliance officer and that the buyer never sees. These are added during setup. They record what your agent flagged. They do not decide whether a report is due, calculate anything, check anything with the authorities or file anything. The flag is raised by your agent. Nothing in the setup reads chats for the word "cash", so the same-day rule above still depends on the agent, which is why it names a person and a step.
What your compliance officer gets is a trail. For any lead, they open the conversation and see what the buyer said, the private note, who wrote it and when, and the flag on the lead. The chat sits on the company number, so it stays when an agent leaves.
Inbox on the shared plan is AED 89 per agent a month for agents 1 to 5 and AED 59 for agents 6 to 20, with a minimum of 3 agents (AED 267 a month). With up to 5 agents you can start with the quick start, a fixed package of AED/SAR 2,500 that we set up for you, with the real estate template and its cash flag field included. Larger teams are set up to a written plan: for 15 agents on the shared plan that is 5 x 89 + 10 x 59 = AED 1,035 a month, with managed setup for 6 to 20 agents at AED/SAR 9,900. Prices exclude VAT, and Meta's WhatsApp fees are billed at cost to your own account. The product page has the full table.
Ticketed requests with a promised reply time belong in Desk. Sales leads that start on WhatsApp go to Inbox. Our post on the Trakheesi permit check covers the other field a brokerage records on the lead.
When is this not for you?
Not for brokerages that never take cash or crypto and say so in writing in their procedure. If that is you, keep the written rule, and keep refusing cash in the chat as well as at the desk.
It is also not for you if nobody owns the lead after the first reply. A cash flag cannot help a chat nobody reads. Start with the five-deal test. Five deals, one named person, one afternoon.
