Should a UAE real estate broker screen the seller as well as the buyer?

UAE
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1

Yes. Sanctions screening is not limited to the buyer. A real estate broker should screen all relevant parties to a transaction, including the seller, the beneficial owners of a corporate seller, and any agent or intermediary, against the UN Consolidated List, the UAE Local Terrorism List and Ministry of Economy notifications. A designated person can appear on either side of a deal, and dealing with a sanctioned seller carries the same freeze-and-report consequences as dealing with a sanctioned buyer.

Screening must be carried out at onboarding, at the point of each transaction, and whenever the sanctions lists are updated. A confirmed match on any party requires the broker to freeze without delay and file a Funds Freeze Report, while a possible match requires a Partial Name Match Report. Limiting screening to buyers alone would leave a clear gap in the broker’s targeted financial sanctions controls. Where a corporate seller is involved, the broker should extend screening to its beneficial owners and any signatory acting on its behalf.

Legal Reference (UAE):

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

3

Yes. The screening obligation is not limited to the buyer. Cabinet Resolution No. 74 of 2020 requires searching the names of the parties related to any transaction, the real beneficiaries, and persons and organisations with whom there is a direct or indirect relationship, in addition to the customer database and potential clients.

In a sale the seller is a party to the transaction, so screening only the buyer leaves a gap on precisely the side that receives the funds. The same logic extends to the beneficial owners behind a corporate seller, and to anyone acting under a power of attorney. The EOCN guidance reinforces the point by requiring screening before processing any transaction of a counterparty, not only at onboarding.

Legal Reference (UAE):

· Cabinet Resolution No. 74 of 2020, Article 21(2): screening of parties to any transaction, real beneficiaries, and directly or indirectly related persons and organisations.

· EOCN Guidance on Targeted Financial Sanctions (March 2026), Step 2: screening before processing any transaction of a counterparty, on list updates, before onboarding, and at periodic review or material change.

Where the position is finely balanced, document your reasoning and raise it with your compliance officer.

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