Is enhanced due diligence required for politically exposed persons buying property in the UAE?
Yes. When a buyer, seller or beneficial owner in a UAE property transaction is a politically exposed person (PEP), the broker must apply enhanced due diligence on top of standard CDD. PEPs hold or have held prominent public functions and present a higher risk of corruption proceeds, so the rules treat them, their family members and close associates with extra caution.
Enhanced measures for a PEP include putting in place risk-management systems to detect PEP status, obtaining senior-management approval before establishing or continuing the relationship, taking reasonable steps to establish the source of wealth and source of funds, and conducting closer ongoing monitoring of the relationship. These steps should be documented in the customer file.
Legal Reference (UAE):
· Cabinet Resolution No. 134 of 2025, Article 16 — sets out the enhanced measures for foreign and domestic PEPs, including senior-management approval and source-of-funds checks.
· Federal Decree-Law No. 10 of 2025, Article 19 — CDD must reflect a risk-based approach.
For more details, consult the full text of Cabinet Resolution No. 134 of 2025 or seek guidance from your AML compliance officer.
A deep dive into AML compliance for the UAE real estate sector