How frequently must UAE real estate brokers screen clients against sanctions lists?
UAE real estate brokers must operate continuous sanctions screening rather than a one-off check. The Targeted Financial Sanctions Guideline issued by the Executive Office for Control and Non-Proliferation requires screening on every customer onboarding, on every KYC review, before executing any property transaction, daily on the live customer database, and within 24 hours of any update to the United Nations Consolidated List or the UAE Local Terrorist List.
In practical terms this means the broker must subscribe to the Notification Alert System (NAS) operated through the goAML portal, configure an automated screening tool against UN, UAE Local and other applicable sanctions lists, and document every screening result, including no-hits. Where a hit is identified, the broker must freeze the funds or property without delay, abstain from any further activity, and submit a Funds Freeze Report (CNMR) on goAML within five business days. Every screening result must be retained for at least five years.
Legal Reference (UAE):
- Cabinet Resolution No. 74 of 2020, Article 21 requires registration on the EOCN Notification Alert System and continuous database screening.
- TFS Guideline (EOCN), Paragraph 30 requires onboarding, periodic, transaction-level and daily database screening with a 24-hour list-update window.
- Cabinet Resolution No. 71 of 2024, Item 27 imposes fines from AED 100,000 to AED 1,000,000 for TFS implementation failures.
For more details, consult the full text of the EOCN TFS Guideline