What are the AML risks of nominee buyers in UAE real estate, and how should brokers respond?

UAE
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A nominee buyer is a person who holds property on paper while another party enjoys the real benefit and control. Nominees are a well-known laundering technique because they break the visible link between the true owner and the asset. In UAE real estate, warning signs include a buyer with no apparent income who purchases high-value property, funds arriving from a third party unconnected to the registered buyer, or a purchaser who appears to be acting on someone else’s instructions.

The broker’s response is to identify the person on whose behalf the transaction is really being conducted and treat that person as the beneficial owner. Under the Real Beneficiary framework, the beneficial owner includes the natural person on whose behalf a transaction is carried out. Nominee directors and shareholders of a corporate buyer must also declare their status. Where a nominee arrangement is suspected and cannot be clarified, the broker should escalate, decline the transaction, and consider a Suspicious Transaction Report.

Legal Reference (UAE):

For more details, consult the full text of the cited law or seek guidance from your AML compliance officer.

AML regulations for real estate agents and brokers in the UAE

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A nominee buyer is the classic case where the person in front of you is not the person whose money is being used. The framework addresses it in two ways: the beneficial owner must be identified, and a nominee shareholder or nominee director must disclose their capacity, the identity of the person they represent or the nominator, and any change within 15 working days.

For a broker the practical test is the one in Article 10. Identify the natural person who ultimately owns 25% or more of the buying entity, and where there is doubt about that person, or doubt that they are genuinely the beneficial owner, or where no natural person controls through ownership, identify the natural person exercising legal or actual control by any other means. If the ownership or control arrangements make that impossible, the position is not a matter of judgment: the firm is prohibited from establishing or continuing the relationship or executing the transaction, and must consider filing a report.

Legal Reference (UAE):

· Cabinet Resolution No. 134 of 2025, Article 10(1): the beneficial owner test including the control fallback; Article 39: nominee disclosure duties.

· Cabinet Resolution No. 134 of 2025, Article 14(1): prohibition on proceeding where customer due diligence cannot be applied, with consideration of a suspicious transaction report.

For your own circumstances, check your internal AML policy or speak to your compliance officer.

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