What identification documents must a real estate agent collect from a corporate property buyer in the UAE?

UAE
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When the buyer or seller is a legal person, a real estate agent must look through the company to the individuals who own and control it. The Ministry of Economy’s Circular 5 of 2022 sets out the documents required for corporate parties: the trade licence, the articles or memorandum of association, the register of beneficial owners, and a copy of the Emirates ID or passport for every beneficial owner as well as for all shareholders or partners.

These requirements align with the wider CDD duty under UAE AML law to identify and verify the ultimate beneficial owner, defined as the natural person who ultimately owns or controls the entity, generally through ownership of 25 percent or more or through other means of control. Corporate layering, nominee arrangements and offshore holding structures must be unpicked rather than accepted at face value.

The agent should verify the documents against reliable sources, keep certified copies on file, and treat any refusal to disclose ownership as a significant red flag warranting enhanced due diligence or a report.

Legal Reference (UAE):

For more details, consult the full text of Cabinet Resolution No. 109 of 2023 or seek guidance from your AML compliance officer.

A deep dive into AML compliance for the UAE real estate sector

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For a corporate buyer the broker must obtain the name, legal form, memorandum of association, tax registration number where the entity is subject to corporate tax, and the unique reference number if any; the address of the registered office or principal place of business, and for a foreign entity the name and address of its legal representative in the UAE with supporting evidence; the articles of association or equivalent approved documents; and the names of the persons holding senior management positions.

Two further steps apply. The identity of anyone acting on behalf of the buyer must be verified and their authority to act confirmed, with the same identification data collected for them. And the broker must understand the nature of the buyer’s business and its ownership and control structure, and the purpose and intended nature of the relationship. Verification must use original documents, data or information from a reliable and independent source.

Legal Reference (UAE):

· Cabinet Resolution No. 134 of 2025, Article 9(1)(b): the basic information required for legal person customers; Article 9(1): verification from reliable and independent sources.

· Cabinet Resolution No. 134 of 2025, Article 9(2) to (4): verifying the authority of persons acting on behalf, understanding the purpose of the relationship, and the ownership and control structure.

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

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