How should a UAE real estate broker handle a buyer that is a trust or legal arrangement?

UAE
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When a buyer is a trust or similar legal arrangement, the broker must look through the structure to identify the natural persons behind it. That means identifying and verifying the settlor, the trustee, any protector, the beneficiaries or class of beneficiaries, and any other natural person exercising ultimate effective control. A trust can obscure who ultimately benefits from a property, so enhanced scrutiny of the arrangement is appropriate.

The broker should obtain the trust deed or equivalent constitutive document, confirm the trustee’s authority to act, and record the beneficial ownership in its CDD file. Where control is exercised through a chain of entities or arrangements, the ownership must be traced through each layer. If the natural persons controlling the arrangement cannot be satisfactorily identified, the broker should not proceed and should consider filing a Suspicious Transaction Report. The trustee should also be asked to confirm whether they are acting for an underlying client, so the broker understands who ultimately controls the funds and the asset.

Legal Reference (UAE):

  • Cabinet Resolution No. 109 of 2023, Article 5: beneficial ownership must be traced through any number of legal persons or arrangements, including where control is exercised by other means.
  • Federal Decree-Law No. 10 of 2025, Article 19(2): the Executive Regulations set obligations relating to legal arrangements, trustees and equivalent positions.

For more details, consult the full text of the cited law or seek guidance from your AML compliance officer.

A deep dive into AML compliance for the UAE real estate sector

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A trust or other legal arrangement is a recognised customer type and the Executive Regulations set out what to obtain. At the identification stage the broker determines that the customer is a legal arrangement and collects the basic information: name, legal form, constitutive document, tax registration number where the entity is subject to corporate tax, unique reference number if any, address of the registered office or principal place of business, articles or equivalent approved documents, and the names of persons in senior management positions. Anyone acting on the arrangement’s behalf must be shown to be authorised and identified in the same way.

Beneficial ownership is where the real work sits. For a legal arrangement the broker must identify the trustee, settlor, trust protector and beneficiaries, or the classes of beneficiaries and the powers granted to them where no beneficiary is identifiable at the time the trust was established. It must also identify any other natural person exercising ultimate effective control, including through a chain of ownership or control, obtain adequate information to identify the beneficial owner at the point of payment or when rights are exercised, and where a legal person is a party to the arrangement, identify that entity’s beneficial owner too. If that picture cannot be completed, the transaction cannot proceed.

Legal Reference (UAE):

· Cabinet Resolution No. 134 of 2025, Article 9(1)(b), which sets out the basic information to be obtained for customers that are legal persons or legal arrangements.

· Cabinet Resolution No. 134 of 2025, Article 10(2), which requires identification of the trustee, settlor, trust protector and beneficiaries or classes of beneficiaries, and of any natural person exercising ultimate effective control.

· Cabinet Resolution No. 134 of 2025, Article 14(1), which prohibits proceeding where customer due diligence measures cannot be applied.

For more details, refer to the Executive Regulations or seek guidance from your AML compliance officer.

Beneficial ownership requirements in the UAE