Are real estate brokers in the UAE required to comply with Targeted Financial Sanctions?
Yes. UAE real estate brokers, as DNFBPs, must comply with Targeted Financial Sanctions (TFS) obligations. This means screening customers, beneficial owners and counterparties against the UAE Local Terrorist List and the United Nations Consolidated List, and applying the instructions issued by the Executive Office for Control and Non-Proliferation without delay.
If a broker identifies a match, it must freeze any related funds immediately, refrain from dealing with the listed party, and report the match to the relevant authorities through the appropriate goAML report, such as a Funds Freeze Report or Partial Name Match Report. Screening should be carried out at onboarding and repeated whenever the sanctions lists are updated. Breaching TFS obligations is a criminal offence.
Legal Reference (UAE):
· Federal Decree-Law No. 10 of 2025, Article 19 — requires immediate implementation of TFS instructions issued by the Executive Office.
· Federal Decree-Law No. 10 of 2025, Article 33 — penalties for violating Targeted Financial Sanctions instructions.
For more details, consult the CBUAE Targeted Financial Sanctions guidance or seek guidance from your AML compliance officer.