What customer due diligence must a UAE real estate broker perform before a property sale?

What customer due diligence must a UAE real estate broker perform before a property sale?

Before establishing a business relationship or completing a property transaction, a UAE real estate broker must identify and verify the customer using reliable, independent source documents, and identify any beneficial owner behind a corporate or nominee buyer. The broker must also understand the purpose and intended nature of the transaction and, on a risk basis, establish the source of funds.

Customer due diligence is not a one-off exercise. Brokers must apply ongoing monitoring throughout the relationship, keep the customer information current, and scale the intensity of checks to the assessed risk. Higher-risk situations call for enhanced due diligence, while clearly low-risk cases may permit simplified measures. All CDD records must be retained and made available to the supervisor on request.

Legal Reference (UAE):

· Federal Decree-Law No. 10 of 2025, Article 19(1)(b) - requires DNFBPs to implement CDD measures and continuous monitoring, retaining the information obtained.

· Cabinet Resolution No. 134 of 2025 (Executive Regulations) - specifies the scope, timing and content of CDD measures.

For more details, consult the Executive Regulations or seek guidance from your AML compliance officer.

A deep dive into AML compliance for the real estate sector