A cross-border payment for property raises the risk profile of a transaction and calls for closer scrutiny. The broker should establish why the funds originate abroad, confirm that the account holder is the buyer or a properly explained third party, and assess whether the sending jurisdiction is high risk. Payments routed through multiple countries, from accounts with no clear connection to the buyer, or from jurisdictions under increased FATF monitoring are recognised red flags.
Where a high-risk-country nexus exists, the broker should apply enhanced due diligence, evidence the source of funds and wealth, and consider filing a High Risk Country Report on goAML in addition to any Real Estate Activity Report. Screening of the remitter and the buyer against sanctions lists remains mandatory. If the explanation for the overseas funding is unsatisfactory, the broker should not proceed and should evaluate whether a Suspicious Transaction Report is warranted.
Legal Reference (UAE):
Federal Decree-Law No. 10 of 2025, Article 19(1)(b): CDD must reflect geographic and other risk dimensions and the national risk assessment.
An overseas transfer is not suspicious by itself, because cross-border property investment is ordinary in the UAE. What it does is put the country of origin, the remitting institution and the source of the funds squarely into the risk assessment. The broker must take into account countries identified by the National Committee as high-risk and those with deficiencies in their anti-money laundering, counter-terrorist financing and proliferation financing systems, and adjust the depth of its enquiry accordingly.
In practice, establish who sent the money and whether that person is the buyer. Funds arriving from an account in a third party’s name, from a jurisdiction with no connection to the buyer, or split across several remittances that each sit below reporting attention are the patterns worth pausing on. Where the country or the customer is high-risk, apply enhanced due diligence: obtain additional information on the source of funds and wealth, seek senior management approval for the relationship, and monitor it more closely afterwards.
Legal Reference (UAE):
· Cabinet Resolution No. 134 of 2025, Article 23(1), which requires enhanced customer due diligence proportionate to the risk where the customer is from a country identified by the National Committee as high-risk or as having deficiencies in its AML, CFT and CPF systems.