How should a UAE real estate broker handle a buyer using a shell company structure?
Shell companies and multi-layered ownership structures are flagged in the UAE Financial Intelligence Unit Real Estate Typology Report as one of the most common layering techniques in property money laundering. When a UAE real estate broker is presented with a corporate buyer that has no apparent operating business, no employees, no physical presence and unclear sources of capital, the relationship must be treated as high risk by default and Enhanced Due Diligence applied.
The broker must trace beneficial ownership through every layer of the structure to identify the natural person who ultimately owns or controls the entity, using the 25 percent ownership and control tests. Where the structure is a foreign chain, the broker must obtain certified registry extracts, organisation charts, and signed UBO declarations supported by passport copies. Source of funds must be independently corroborated, sanctions and PEP screening must be performed on every layer, and senior-management approval must be obtained before onboarding. If the structure cannot be unmasked or the rationale cannot be explained, the broker must decline the transaction and file an STR through goAML.
Legal Reference (UAE):
- Cabinet Resolution No. 109 of 2023, Article 5 sets the cascade for identifying real beneficiaries.
- Cabinet Resolution No. 134 of 2025, Article 10 imposes UBO verification; Article 14 requires the firm to refuse the relationship where CDD cannot be completed.
For more details, consult the full text of Cabinet Resolution 109 of 2023
The complete guide to ultimate beneficial owner verification