How do you verify source of funds in a UAE real estate transaction?

UAE
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Verifying the source of funds in a UAE real estate transaction means establishing where the money used to buy the property actually came from and confirming it with reliable evidence. It is a central part of due diligence, especially for high-value or higher-risk deals.

The broker asks the buyer to explain the origin of the funds and then supports that explanation with documents such as bank statements, salary or business income records, proof of sale of other assets, loan or mortgage agreements, or inheritance and gift documentation. For corporate buyers, the broker examines the company financials and the flow of funds through the ownership structure. The information gathered should be consistent with the customer profile and the value of the property. Where the source of funds cannot be verified, or the explanation does not match the evidence, this is a strong red flag that calls for enhanced due diligence and, if unresolved, a suspicious transaction report. Source of wealth may also be required for PEPs and other high-risk customers.

Legal Reference (UAE):

For more details, consult the full text of Cabinet Resolution 134/2025 or seek guidance from your AML compliance officer.

A complete guide to effective customer due diligence

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Source of funds sits inside the ongoing monitoring obligation. A broker must scrutinise transactions throughout the relationship to ensure they are consistent with the information held about the customer, the nature of their activities and the risks they present, including, where necessary, the source of funds.

Where the buyer is a politically exposed person the position hardens: reasonable measures to identify the source of funds and the source of wealth of the customer and beneficial owner are a mandatory enhanced measure for foreign PEPs, and apply to domestic PEPs and international organisation PEPs where the relationship is high risk. In practice verification means independent corroboration rather than a signed declaration: documents evidencing the transaction that generated the funds, from a reliable and independent source, consistent with what you already know about the buyer’s profile.

Legal Reference (UAE):

· Cabinet Resolution No. 134 of 2025, Article 8(1): scrutiny of transactions for consistency with the customer profile, including source of funds where necessary.

· Cabinet Resolution No. 134 of 2025, Article 16(1)(a)(3) and (b): source of funds and wealth as a mandatory enhanced measure for foreign PEPs, and for domestic and international-organisation PEPs in high-risk relationships.

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

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