When does a real estate broker need senior management approval to onboard a buyer in the UAE?
Senior management approval is required before a UAE real estate broker establishes or continues a business relationship in three categories of higher-risk cases. The first is any Politically Exposed Person, including foreign PEPs, domestic PEPs, family members and known close associates. The second is any customer or beneficial owner connected to a high-risk jurisdiction identified by FATF, the National Risk Assessment, or any local high-risk list. The third is any other case where the firm’s risk-based methodology classifies the customer, transaction or geography as high risk.
In practice this means that the AML Compliance Officer escalates the case to a designated senior manager (or to the board where the firm has a board) with a written EDD memorandum summarising the risk drivers, the additional documents collected, the source of funds and source of wealth findings, and the proposed mitigants. The senior manager must record the approval, the date and any conditions, all of which must be retained on file. Where senior management does not approve, the broker must decline the transaction and consider whether an STR is warranted.
Legal Reference (UAE):
- Cabinet Resolution No. 134 of 2025, Article 5 requires senior-management approval as part of EDD; Article 16 requires it for PEPs; Article 23 requires it for high-risk countries.
For more details, consult the full text of Cabinet Resolution 134 of 2025