When is enhanced due diligence required in UAE real estate transactions?
Enhanced due diligence (EDD) is required in UAE real estate whenever a business relationship or transaction presents higher money laundering risk. Common triggers include buyers who are politically exposed persons or connected to them, customers or structures from high-risk jurisdictions, complex or opaque ownership, unusually large or structured payments, and deals involving virtual assets.
EDD measures go beyond standard CDD. They can include obtaining and verifying additional information on the customer and beneficial owner, taking reasonable steps to establish the source of funds and wealth, increasing ongoing monitoring, and obtaining senior management approval before commencing or continuing the relationship. The depth of EDD should be proportionate to the level of risk identified through the broker risk-based approach.
Legal Reference (UAE):
· Cabinet Resolution No. 134/2025 (Executive Regulations), Article 5 - lists enhanced due diligence measures for managing and mitigating identified risks.
· Cabinet Resolution No. 134/2025 (Executive Regulations), Article 23 - requires EDD for customers connected to high-risk countries.
For more details, consult the full text of the Executive Regulations or seek guidance from your AML compliance officer.
Enhanced due diligence (EDD) is required in UAE real estate whenever a business relationship or transaction presents higher money laundering risk. Common triggers include buyers who are politically exposed persons or connected to them, customers or structures from high-risk jurisdictions, complex or opaque ownership, unusually large or structured payments, and deals involving virtual assets.
EDD measures go beyond standard CDD. They can include obtaining and verifying additional information on the customer and beneficial owner, taking reasonable steps to establish the source of funds and wealth, increasing ongoing monitoring, and obtaining senior management approval before commencing or continuing the relationship. The depth of EDD should be proportionate to the level of risk identified through the broker risk-based approach.
Legal Reference (UAE):
· Cabinet Resolution No. 134/2025 (Executive Regulations), Article 5 - lists enhanced due diligence measures for managing and mitigating identified risks.
· Cabinet Resolution No. 134/2025 (Executive Regulations), Article 23 - requires EDD for customers connected to high-risk countries.
For more details, consult the full text of the Executive Regulations or seek guidance from your AML compliance officer.