What record must a UAE real estate broker keep of the customer due diligence it performs?

UAE
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A broker must keep a full and retrievable record of the customer due diligence it carries out. That includes copies of the identity documents obtained, the Emirates ID or passport of natural persons, and for legal persons the trade licence, articles of association, register of beneficial owners and identity documents for all beneficial owners and shareholders. It also includes the transaction documents such as receipts, invoices, contracts and the purchase and sale agreement, the risk assessment of the customer, records of screening carried out, and any decision on whether to report.

These records must be retained for at least five years and be immediately available to the competent authorities on request. The purpose is to allow a supervisor or the Financial Intelligence Unit to reconstruct exactly what the broker knew and did. Records kept only in fragmented or informal form will not satisfy the obligation, so brokers should maintain an organised CDD file for each customer and transaction.

Legal Reference (UAE):

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

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

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The broker must retain the records and documents obtained through customer due diligence and ongoing monitoring. That expressly includes account files, business correspondence, copies of personal identification documents, suspicious transaction reports, the results of any analysis conducted, and CCTV and related ATM recordings.

Two qualities matter as much as the list. The records must be organised so that individual transactions can be reconstructed, data analysed and financial transactions traced, to the point of being capable of providing evidence for a prosecution. And all customer information, including the due diligence and monitoring results, must be made available to the concerned authorities promptly on request. A file that exists but cannot be retrieved quickly does not meet the second requirement.

Legal Reference (UAE):

· Cabinet Resolution No. 134 of 2025, Article 25(2): the categories of due diligence record to retain for not less than five years.

· Cabinet Resolution No. 134 of 2025, Article 25(3) and (4): organisation permitting reconstruction and evidential use, and prompt availability to authorities on request.

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

AML/CFT policy, controls and procedures documentation