What freezing actions must a UAE real estate broker take when a buyer matches a sanctions list?
When a UAE real estate broker identifies a true match between a buyer, seller, beneficial owner or related party and a designated person on the United Nations Consolidated List or the UAE Local Terrorist List, the broker must act without delay. The first step is to freeze the funds, the property under transaction, and any other assets the broker holds for the designated person, and to refrain from executing any further service or transfer.
The second step is to file a Confirmed Name Match Report (CNMR) on the goAML portal within five business days of the freeze, attaching the title deed or sale and purchase agreement, the customer ID documents, and the property details including type, value and location. The broker must not tip off the designated person or any third party. The freeze remains in place until the Executive Office for Control and Non-Proliferation issues a written de-listing or release instruction. All actions, screening evidence and communications must be retained for at least five years and made available to the supervisor on request.
Legal Reference (UAE):
- Cabinet Resolution No. 74 of 2020, Article 21 sets the registration and screening duties.
- TFS Guideline (EOCN), Paragraph 46 requires the CNMR within five business days and five-year retention; Section 4 illustrates the real-estate freeze case.
- Federal Decree-Law No. 10 of 2025, Article 33 sets imprisonment plus fines from AED 20,000 for violating EOCN/TFS instructions.
For more details, consult the full text of the EOCN TFS Guideline