What AML measures must a UAE real estate agent take when suspicious or forged documents are presented?
When a real estate broker encounters documents during the CDD process that appear suspicious, altered, or potentially forged (such as a passport with inconsistent security features, a trade licence that does not match registry records, or a Register of Beneficial Owners that lists no identifiable individuals), this constitutes a significant AML red flag and triggers both reporting and operational obligations.
The broker must not proceed with the transaction until the authenticity of the documents has been established to a reasonable standard. Where the broker cannot confirm authenticity, Cabinet Resolution No. 134 of 2025 requires that the business relationship be declined or terminated, and the broker must consider filing a Suspicious Transaction Report with the FIU via the goAML portal. The broker must not alert the customer that an STR is being filed.
The Supplemental Guidance for the Real Estate Sector specifically identifies the use of fraudulent or forged documents as a key typology in real estate-based money laundering, particularly in transactions where the broker or legal professional acts in a fiduciary or secretarial capacity regarding title deeds, financial instruments, or contracts. Staff training should include the identification of common document fraud indicators, and brokers should use official registry verification channels where available.
Legal Reference (UAE):
- Cabinet Resolution No. 134 of 2025, Article 14(1) - prohibits DNFBPs from proceeding with a transaction where CDD cannot be properly applied, and requires consideration of an STR filing
- Ministry of Economy Supplemental Guidance for the Real Estate Sector, Section 11.3.4 - highlights fraudulent and forged documents as a significant CDD risk typology specific to the real estate sector
For more details, consult the full text of Cabinet Resolution No. 134 of 2025
AML Compliance Requirements for the Real Estate Sector in the UAE