What should a UAE real estate broker do when customer due diligence on a buyer cannot be completed?

UAE
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If a broker cannot complete customer due diligence, for example because the buyer refuses to provide identity or beneficial-owner information or the documents cannot be verified, the broker must not proceed with the transaction. The obliged entity should decline to establish or continue the business relationship and must consider whether the failure itself gives grounds to file a Suspicious Transaction Report with the Financial Intelligence Unit.

A refusal to disclose ownership, an unexplained reluctance to evidence source of funds, or inconsistent documentation are recognised red flags in property laundering. The broker should document the decision, retain the partial CDD file, and avoid tipping off the customer about any report filed. Where the incomplete CDD relates to a legal-person buyer whose beneficial owner cannot be identified, the transaction should be halted rather than completed on incomplete records. Halting the deal, and filing a report where appropriate, protects the broker because the file shows the CDD failure that justified the decision.

Legal Reference (UAE):

  • Federal Decree-Law No. 10 of 2025, Article 19(1)(b): CDD measures must be implemented and the information retained; the Executive Regulations set the conditions for identification.
  • Federal Decree-Law No. 10 of 2025, Article 18(1): obliged entities must report to the Unit without delay where they suspect funds relate to a crime.

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

AML regulations for real estate agents and brokers in the UAE

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The rule is a prohibition, not a discretion. Where a broker is unable to apply customer due diligence measures, it is prohibited from establishing or continuing the business relationship or executing the transaction, and it must consider submitting a suspicious transaction report to the Financial Intelligence Unit. In a property context that means standing the deal down rather than proceeding on an incomplete file and promising to catch up later.

There is one important qualification. Where the broker suspects a crime and has reasonable grounds to believe that pursuing due diligence would alert the customer, it may refrain from applying those measures, but it must then file a suspicious transaction report stating the reasons for not applying them. Either way the reason for stopping is recorded on the file, and the customer is never told that a report has been or may be made. Record keeping obligations still run for the abandoned matter.

Legal Reference (UAE):

· Cabinet Resolution No. 134 of 2025, Article 14(1), which prohibits establishing or continuing a business relationship or executing a transaction where customer due diligence cannot be applied, and requires consideration of a suspicious transaction report.

· Cabinet Resolution No. 134 of 2025, Article 14(2), which allows an entity to refrain from applying customer due diligence where doing so would tip off the customer, provided a report is filed stating the reasons.

· Cabinet Resolution No. 134 of 2025, Article 19(1), which prohibits disclosing to the customer that a report has been or will be submitted.

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

Customer due diligence requirements in the UAE