Legal & RegulatoryCompliance Officer
Synonyms: AML Compliance Officer، MLRO، Chief Compliance Officer
Last updated: 2026-09-25
Short Definition
A compliance officer is the person within an organisation responsible for ensuring it complies with the laws, regulations and instructions that apply to its business, setting internal policies and procedures, monitoring their application and reporting to senior management and the authorities when needed.
Overview
A compliance officer is the person within an organisation responsible for ensuring it complies with the laws, regulations and instructions that apply to its business, setting internal policies and procedures, monitoring their application and reporting to senior management and the authorities when needed. In real estate offices and companies the role centres on anti-money laundering, compliance with the Real Estate Brokerage Law and Fal licensing, and personal data protection.
The clearest legal basis for the role in real estate is the Anti-Money Laundering Law issued by Royal Decree M/20 dated 5/2/1439H and its implementing regulations. The regulations list real estate brokerage among designated non-financial businesses and professions when brokers are involved in transactions for clients concerning the buying and selling of real estate, and require covered entities to have compliance management arrangements, including appointing an AML compliance officer at senior management level. The officer’s work includes customer and beneficial-owner due diligence (Article 7), reporting suspicious transactions to the General Directorate of Financial Intelligence (Article 15) without tipping off the customer (Article 16), and keeping records for at least ten years (Article 12). The Real Estate General Authority (REGA) has issued guidelines for brokers on beneficial-owner due diligence.
The compliance officer also monitors compliance with the Real Estate Brokerage Law (Royal Decree M/130 dated 30/11/1443H): valid Fal licences for the firm and its staff, written brokerage contracts, licence numbers in advertisements and electronic documentation of contracts — with fines of up to SAR 200,000. He also follows the Personal Data Protection Law, whose regulations define when a data protection officer must be appointed. In small offices one person may combine these tasks, but the appointment should be documented and the powers clearly defined.
⚖️ Legal Basis
Anti-Money Laundering Law issued by Royal Decree M/20 dated 5/2/1439H: Article 7 (due diligence), Article 12 (record-keeping for at least ten years), Article 14 (internal policies and procedures), Article 15 (suspicious transaction reporting) and Article 16 (tipping-off prohibition), together with its implementing regulations, which cover real estate brokerage and require an AML compliance officer at senior management level. Real Estate Brokerage Law issued by Royal Decree M/130 dated 30/11/1443H (licensing; fines up to SAR 200,000). Personal Data Protection Law (Article 30 as amended).
💡 Practical Example
A Riyadh brokerage that sells villas and land to individual and corporate clients appoints its operations manager as compliance officer by a documented decision and adopts a written procedure to verify each client’s identity and beneficial owner and record the source of funds. A buyer seeks to purchase land for SAR 3,200,000 through a newly formed company, refuses to disclose its owners and pushes for a quick closing. The compliance officer halts the process, assesses the red flags, files a report with the General Directorate of Financial Intelligence without tipping off the client, and keeps the documents for ten years. Separately, he checks monthly that the Fal licences of the office’s five staff are valid (SAR 300 a year per individual licence), avoiding fines of up to SAR 200,000.
⚠️ Common Mistakes
- ✗Believing AML duties apply only to banks — real estate brokerage in purchase and sale transactions is covered as a designated non-financial business.
- ✗Appointing a nominal compliance officer with no authority or access to records — the role must sit at senior management level and be empowered to act.
- ✗Alerting the client that a report has been filed or suspicion exists — prohibited by Article 16 of the AML Law.
- ✗Destroying transaction files soon after closing — records must be kept for at least ten years.
- ✗Failing to track the expiry of staff Fal licences — brokering without a valid licence exposes the firm to fines of up to SAR 200,000.
🌍 International Differences
FATF recommendations extend AML obligations to real estate agents in most countries. In the UAE, real estate brokers are subject to due diligence and reporting duties as designated non-financial businesses; in the UK, estate agents must register with a supervisor and appoint a money laundering reporting officer (MLRO); in Turkey, those engaged in buying and selling real estate have reporting obligations to the financial intelligence unit MASAK. A distinctive Saudi feature is REGA’s sector-specific guidance for brokers, linked to Fal licensing.
FAQs
Must a real estate office appoint a compliance officer?▾
If the office brokers purchases and sales of real estate, it is a designated non-financial business under the AML Law’s implementing regulations, which require compliance arrangements including an AML compliance officer at senior management level.
What are a real estate compliance officer’s core duties?▾
Customer and beneficial-owner due diligence, reporting suspicious transactions to the General Directorate of Financial Intelligence, record-keeping, and monitoring Fal licences, brokerage obligations and data protection.
How long must transaction records be kept?▾
At least ten years from the date the transaction is concluded or the account is closed, under Article 12 of the Anti-Money Laundering Law.
Can a client be told that his transaction has been reported?▾
No. Article 16 of the AML Law prohibits the business and its staff from disclosing to the client or anyone else that a report will be, is being or has been filed, or any related information.
How does the compliance officer relate to the Real Estate Brokerage Law?▾
He tracks the validity of the firm’s and staff’s Fal licences, written brokerage contracts and licence numbers in advertisements, since breaches of the Brokerage Law can draw fines of up to SAR 200,000.
