Are real estate brokers required to conduct customer due diligence before completing a property sale in the UAE?

UAE
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Yes. Customer due diligence is a core obligation for real estate brokers as DNFBPs, and it must be carried out before or during the establishment of the business relationship, not after the deal has closed. UAE AML law requires DNFBPs to identify and verify the customer and any beneficial owner, understand the purpose and intended nature of the transaction, and conduct ongoing monitoring, all calibrated to the risk of the particular deal.

For a property sale this means verifying the identity of both buyer and seller using reliable documents such as the Emirates ID or passport, establishing beneficial ownership for corporate parties, and assessing the source of funds. The scope of the checks scales with risk: a straightforward salaried resident buyer sits at the lower end, while a foreign buyer using a complex offshore structure or virtual assets calls for enhanced measures.

Completing a transaction without adequate CDD is a breach that can attract administrative penalties, and it deprives the broker of the information needed to spot and report suspicious activity.

Legal Reference (UAE):

For more details, consult the full text of Cabinet Resolution No. 134 of 2025 or seek guidance from your AML compliance officer.

A deep dive into AML compliance for the UAE real estate sector

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Yes. Customer due diligence must be applied on the commencement of a business relationship, where there is suspicion of a crime, and where there are doubts about the accuracy or adequacy of customer identification data previously obtained. Identity must be verified before or during the establishment of the relationship, or before carrying out a transaction for a customer with whom no relationship exists.

Deferral is possible but narrow. In cases of low crime risk verification may be completed after the relationship is established, provided it is completed as soon as possible, the deferral is necessary so as not to disrupt normal business, and appropriate and effective measures control the risk. Where the customer can benefit from the relationship before verification is complete, the broker must take measures to manage that risk.

Legal Reference (UAE):

· Cabinet Resolution No. 134 of 2025, Article 7(1): the three cases where CDD applies; Article 6(1): verification before or during establishment of the relationship.

· Cabinet Resolution No. 134 of 2025, Article 6(2) and (3): the conditions for deferring verification and managing risk in the interim.

Where the position is finely balanced, document your reasoning and raise it with your compliance officer.

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