How should a UAE real estate agent handle a politically exposed person (PEP) buyer?
A politically exposed person (PEP) is treated as higher risk, so a UAE real estate agent must apply enhanced due diligence when a buyer, or a beneficial owner behind the buyer, is identified as a PEP. This applies to foreign PEPs and, on a risk-sensitive basis, to domestic PEPs and heads of international organisations, together with their family members and close associates.
The enhanced measures include obtaining senior management approval before entering into or continuing the relationship, taking reasonable steps to establish the PEP’s source of funds and source of wealth, and applying closer ongoing monitoring of the relationship and its transactions. The agent should document why the customer was classified as a PEP and record the additional checks performed, so the firm can demonstrate a proportionate, risk-based response to its supervisor.
Legal Reference (UAE):
· Federal Decree-Law No. 10 of 2025, Article 19(1)(a) and (b) - require a risk-based approach and CDD scaled to risk, which for PEPs means enhanced measures.
· Cabinet Resolution No. 134 of 2025 (Executive Regulations) - sets out the specific PEP obligations, including senior management approval and source of funds checks.
For more details, consult the Executive Regulations or seek guidance from your AML compliance officer.