What ongoing monitoring must a UAE real estate broker perform on an existing customer relationship?

UAE
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Customer due diligence is not a one-off exercise at onboarding. The Federal Decree-Law requires obliged entities to implement CDD and continuous monitoring procedures throughout the business relationship. For a real estate broker with a repeat client, this means keeping identity and beneficial-owner information current, watching that transactions remain consistent with what is known about the customer, and re-screening the parties against sanctions lists whenever the lists are updated.

Ongoing monitoring is risk-based, so higher-risk customers are reviewed more frequently and in more depth than low-risk ones. Triggers for a fresh review include a change in ownership or control of a corporate client, a transaction that is unusually large or structured, a new source of funds, or the emergence of adverse information. Where monitoring surfaces activity that no longer makes commercial sense or raises suspicion, the broker must consider filing a Suspicious Transaction Report and refreshing its CDD before continuing.

Legal Reference (UAE):

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

MoET supplemental guidance for real estate agents and brokers

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Ongoing monitoring has two limbs. Scrutinise transactions carried out throughout the business relationship to ensure they are consistent with the information held about the customer, the nature of their activities and the risks they present, including where necessary the source of funds. And ensure that documents, data and information obtained during customer due diligence remain up to date and relevant by reviewing records.

The second limb expressly requires particular emphasis on records relating to categories of high-risk customers. For a brokerage with repeat clients this means a stale file on a high-risk buyer is itself a monitoring failure, even where no unusual transaction has occurred. Customer due diligence measures must also be applied to existing relationships at such times as the business considers appropriate based on materiality and risk.

Legal Reference (UAE):

· Cabinet Resolution No. 134 of 2025, Article 8(1) and (2): transaction scrutiny including source of funds where necessary, and keeping CDD records current with emphasis on high-risk customers.

· Cabinet Resolution No. 134 of 2025, Article 13: applying CDD measures to existing customers and relationships based on materiality and risk.

Where the position is finely balanced, document your reasoning and raise it with your compliance officer.

Ongoing monitoring software