Qatar: from 1 January 2027, real estate brokers move to a new AML/CFT supervisor
Qatar’s Council of Ministers has rewritten the article that says who supervises whom for anti-money laundering and counter-terrorist financing (AML/CFT). Council of Ministers Decision No. (38) of 2026 replaces Article 59 of the Implementing Regulations of the AML/CFT Law, issued by Council of Ministers Decision No. (41) of 2019. The new table gives real estate brokers to the General Authority for Real Estate Sector Regulation. Under the 2019 text, real estate agents sat with the Ministry of Justice.
The QFC Regulatory Authority (QFCRA) lists the decision on its AML/CFT legislation page and links to an Arabic scan of the signed text. We found no English version. We read that scan, with an OCR cross-check. The English names below are our own translation, not an official one.
Three dates, three meanings
- Issued: 15 September 2026. The decision records that it was issued at the Amiri Diwan on 4/4/1448 AH, corresponding to 15/9/2026. Both dates are handwritten on the scan.
- In force: 1 January 2027. Article 2 says the decision is effective from 1/1/2027.
- Published: not confirmed by us. Article 2 also says the decision is to be published in the Official Gazette. We could not open Al Meezan, the official legal portal, so we have not confirmed the publication date.
Until 1 January 2027 the decision does not take effect, so the current Article 59 still applies. That is our reading of Article 2.
What the new Article 59 says
The decision has two articles. Article 1 replaces the text of Article 59. Article 2 tells all competent authorities, each within its remit, to implement it, and sets the date.
The new Article 59 makes the listed supervisory authorities competent to monitor, follow up and supervise the compliance of the sectors shown against each of them with AML/CFT requirements. Here is the table before and after.
| Supervisor | 2019 text (QFCRA’s unofficial English translation) | From 1 Jan 2027 (our translation of the Arabic) |
|---|---|---|
| Qatar Central Bank | Banks and exchange houses; MVTS providers; insurance and reinsurance; finance and investment companies | Banks and exchange houses; money or value transfer service providers; insurance and reinsurance; finance and investment companies |
| Qatar Financial Markets Authority | Financial brokerage firms; Qatar Stock Exchange; Qatar Central Securities Depository | The same three |
| Ministry of Justice | Lawyers; notaries; real estate agents | Lawyers; authorised notaries |
| Ministry of Commerce and Industry | Legal accountants; traders in precious metals and stones; trust and company service providers | Legal accountants; dealers in precious metals or precious stones; trust and company service providers |
| QFC Regulatory Authority | Financial institutions and DNFBPs established in the Qatar Financial Centre | Financial institutions and DNFBPs established in the Centre |
| General Authority for Real Estate Sector Regulation | Not listed | Real estate brokers |
| Regulatory Authority for Charitable Activities | Non-profit organisations | Non-profit organisations |
The 2019 table has six rows. The new one has seven. The closing sentence stays: supervisory authorities also include any other body with legal power to regulate, supervise or monitor financial institutions, DNFBPs or non-profit organisations.
Two points of translation. The new row 6 uses the Arabic term الوسطاء العقاريون (“real estate brokers”), which the QFCRA’s English text of the 2019 regulations renders as “real estate agents” in Article 59. The new Ministry of Justice row reads الموثقون المفوضون (“authorised notaries”). We did not have the 2019 Arabic text, so we do not say whether that wording is new.
Who the new supervisor is
The decision’s preamble cites Amiri Decision No. (28) of 2023 establishing the General Authority for Real Estate Sector Regulation, as amended by Amiri Decision No. (34) of 2026. It also cites Law No. (22) of 2017 regulating real estate brokerage, as amended by Law No. (13) of 2026, and says the decision follows a proposal by the Chairman of the National Anti-Money Laundering and Terrorism Financing Committee.
We have not read those instruments, and no source we trust sets out the authority’s AML/CFT powers or plans. We therefore say nothing about how it will supervise.
What does not change
The decision replaces Article 59 and nothing else. The brokers’ duties come from other articles that it does not touch.
- They remain DNFBPs. The AML/CFT Law, Law No. (20) of 2019, defines DNFBPs to include real estate agents whenever they conduct transactions for customers relating to the sale or purchase of real estate, or both.
- Who supervises is set by the Implementing Regulations. The Law defines supervisory authorities as competent authorities responsible for licensing or supervising financial institutions, DNFBPs and non-profit organisations, or for ensuring their AML/CFT compliance, “as stipulated in the Implementing Regulations”. That is why a Council of Ministers decision can move a sector.
- The CDD rule for property deals. Article 10 of the Implementing Regulations applies CDD to occasional transactions of QR 50,000 or more, and says real estate agents must perform CDD on both the purchaser and the vendor of the property.
Three things worth doing
These are our suggestions, not requirements of the decision.
- Brokers: plan the hand-over now. Update the supervisor named in your AML/CFT policy, risk assessment and reporting procedures, with 1 January 2027 as the switch date. Until then, keep dealing with the Ministry of Justice.
- Banks and other firms: update supervisor fields. If your customer or counterparty records hold “supervisor: Ministry of Justice” for Qatari real estate brokers, schedule the change for 1 January 2027. Leave lawyers and notaries where they are; their row did not move.
- Watch for the new supervisor’s instructions. The decision says nothing about guidance, returns or inspections. Check the authority’s own announcements and the Official Gazette.
Sources
This article draws on the following sources. Follow the links for the original text.
- Council of Ministers — Decision No. (38) of 2026 amending some provisions of the Implementing Regulations of the AML/CFT Law (Arabic, signed scan hosted by the QFCRA)
- Council of Ministers — Implementing Regulations of Law No. (20) of 2019 (unofficial English translation hosted by the QFCRA)%20of%202019.pdf)
- State of Qatar — Law No. (20) of 2019 on Combating Money Laundering and Terrorism Financing (unofficial English translation hosted by the QFCRA)%20of%202019%20on%20Combating%20Money%20Laundering%20and%20Terrorism%20Financing%20(1).pdf)
- QFCRA — AML/CFT Law and Legislation
For information only. This briefing is not legal advice: check the cited sources and take advice on your own position.
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