Must a UAE real estate broker identify the beneficial owner of a corporate buyer?
Yes. Where the buyer or seller is a legal person, a UAE real estate broker must look through the corporate structure and identify the beneficial owner, meaning the natural person who ultimately owns or controls the entity. Verifying the person named on the title is not sufficient if that person is acting for, or is owned by, someone else.
The beneficial owner is generally the individual holding a controlling ownership interest; where no such person can be identified, control exercised by other means is assessed, and failing that the senior managing official is treated as the beneficial owner. Brokers should obtain the entity’s beneficial owner register, shareholder details, and identity documents for each beneficial owner, and confirm that the information is accurate and not being submitted on behalf of an undisclosed third party.
Legal Reference (UAE):
· Cabinet Resolution No. 109 of 2023 on Real Beneficiary Procedures, Article 5 - sets out how the real beneficiary of a legal person is determined.
· Federal Decree-Law No. 10 of 2025, Article 19(1)(b) - requires identification of the customer and beneficial owner as part of CDD.
For more details, consult Cabinet Resolution No. 109 of 2023 or seek guidance from your AML compliance officer.