For a qualifying transaction of AED 55,000 or more, a dealer must identify and verify the customer before or while the dealing is carried out. For a resident individual this means a valid Emirates ID, and for a non-resident individual a passport or other government-issued identity document. For a corporate customer the dealer must obtain a valid trade licence together with an identity document for the authorised representative acting on the company’s behalf.
The dealer should also record the details of the transaction itself, including the goods, the value and the payment method, and where risk indicators are present, take reasonable steps to understand the source of funds and the beneficial owner behind a company. All of this information supports the DPMSR filing and must be retained. Verification cannot be skipped simply because a customer is a repeat buyer.
For a natural person the dealer must obtain the name as stated in the identity card or travel document, nationality, address, date and place of birth, and where applicable the name and address of the employer, together with a true copy of a valid identity card or travel document.
For a legal person the basic information required is the name, legal form, memorandum of association, tax registration number where the entity is subject to corporate tax, and unique reference number if any; the registered office or principal place of business address, and for a foreign entity the name and address of its UAE legal representative with supporting evidence; the articles of association or equivalent approved documents; and the names of persons in senior management positions. The dealer must also verify that anyone acting on the customer’s behalf is authorised, identify the beneficial owner, and understand the purpose of the relationship and the customer’s ownership and control structure.
Legal Reference (UAE):
· Cabinet Resolution No. 134 of 2025, Article 9(1)(a) and (b): the identification data required for natural and legal persons, verified from reliable and independent sources.
· Cabinet Resolution No. 134 of 2025, Article 9(2) to (4): authority of persons acting on behalf, purpose of the relationship, and ownership and control structure; Article 10: beneficial owner identification.
Where the position is finely balanced, document your reasoning and raise it with your compliance officer.