Do UAE real estate brokers need to check clients against sanctions lists?
Yes. UAE real estate brokers must screen customers and beneficial owners against the UAE Local Terrorist List and the United Nations Consolidated Sanctions List as part of their targeted financial sanctions (TFS) obligations. Screening must be done at onboarding and on an ongoing basis, because listings can change during a relationship.
If a broker identifies a match, it must freeze any funds or assets without delay, refrain from dealing with the listed party, and report to the Executive Office and the FIU as required. TFS obligations are strict and immediate; unlike suspicion-based reporting, a confirmed match requires prompt freezing action. Brokers should use reliable screening tools and keep evidence of the checks performed.
Legal Reference (UAE):
· Cabinet Resolution No. 74/2020 on Terrorist Lists and UN Security Council Resolutions - governs targeted financial sanctions and freezing obligations.
· Cabinet Resolution No. 134/2025 (Executive Regulations), Article 5 - requires measures ensuring full implementation of targeted financial sanctions instructions.
For more details, consult CBUAE targeted financial sanctions guidance or seek guidance from your AML compliance officer.