How do real estate brokers identify the ultimate beneficial owner of a corporate buyer?
To identify the ultimate beneficial owner (UBO) of a corporate buyer, a UAE real estate broker works through the ownership chain to find the natural person who ultimately owns or controls the company. Under UAE rules the starting point is any individual who holds 25% or more of the company’s capital or voting rights. Where no such person exists, or where ownership is held through layers of other entities, the broker looks to whoever otherwise exercises ultimate control, and as a last resort the senior managing official.
Brokers should obtain the company’s register of beneficial owners, cross-check it against the articles of association and shareholding documents, and verify the identity of each UBO with an Emirates ID or passport. Complex or opaque structures designed to obscure ownership are a money laundering red flag and call for enhanced due diligence.
Legal Reference (UAE):
· Cabinet Resolution No. 109 of 2023, Article 4 — the real beneficiary is whoever owns or controls 25% or more of capital or voting rights, then whoever exercises control by other means.
· Cabinet Resolution No. 134 of 2025, Article 5 — CDD includes identifying and verifying the beneficial owner.
For more details, consult the full text of Cabinet Resolution No. 109 of 2023 or seek guidance from your AML compliance officer.
A deep dive into AML compliance for the UAE real estate sector