Do UAE real estate firms have to screen buyers against sanctions lists?
Yes. UAE real estate firms must screen customers, beneficial owners and relevant counterparties against the United Nations Security Council consolidated list and the UAE Local Terrorist List, and act immediately on any match. Screening is required at onboarding, before concluding a transaction, and whenever the sanctions lists are updated.
If a name matches a designated person or entity, the firm must not proceed with the transaction, must freeze any funds without delay, and must file a Funds Freeze Report through goAML, notifying the Executive Office and the Financial Intelligence Unit. Partial matches should be reviewed and, where they cannot be cleared, reported as a Partial Name Match Report. Firms should keep their screening tools current so that newly designated names are captured promptly.
Legal Reference (UAE):
· Federal Decree-Law No. 10 of 2025, Article 19(1)(e) - requires immediate implementation of instructions on Targeted Financial Sanctions issued by the Executive Office.
· Cabinet Resolution No. 74 of 2020 on the Terrorist Lists - governs the terrorist lists and implementation of Security Council resolutions.
For more details, consult the TFS guidance or seek guidance from your AML compliance officer.