How should a UAE real estate broker verify a buyer’s source of funds?
Verifying a buyer’s source of funds is a CDD obligation for every UAE real estate transaction and an Enhanced Due Diligence obligation for every high-risk customer. The broker must understand both the immediate source of the payment, meaning the account or wallet from which funds arrive, and the underlying source of wealth, meaning how the buyer accumulated the money in the first place. Self-declarations alone are not sufficient where risk indicators are present.
Acceptable evidence depends on the buyer’s profile. For salaried individuals it usually includes recent payslips, an employment letter and bank statements showing salary credits. For business owners it includes audited financial statements, dividend or distribution records and corporate bank statements. For inheritances it includes the will, succession order or executor’s certificate. For investment proceeds it includes brokerage statements and capital-gains records. For property reinvestments it includes the prior title deed and bank confirmation of the sale proceeds. The broker must check the documents are consistent with the transaction value and date, and document any gaps. Where the source cannot be verified, the broker must decline the transaction and consider an STR.
Legal Reference (UAE):
- Cabinet Resolution No. 134 of 2025, Article 5 mandates source-of-funds inquiry as part of EDD; Article 16 requires source-of-funds for PEPs.
- Federal Decree-Law No. 10 of 2025, Article 19 requires risk-based preventive measures.
For more details, consult the full text of Cabinet Resolution 134 of 2025
The significance of cash thresholds in fighting money laundering