UAE: serving expat buyers, documents and client checks

Buyers who live outside the UAE, or who hold a different citizenship from the country they live in, are a normal part of the Dubai and Abu Dhabi market. For the broker they bring two sets of duties: the licence and advertising rules that apply to every sale, and the anti-money-laundering duties that apply to every client. This briefing lists both and marks what we could not confirm from a primary source.

Be licensed and visible

• In Dubai a brokerage holds a trade licence and is registered with RERA, and each agent holds a personal broker card number (BRN) under the firm. A practice guide also lists the broker agreements and the advertising permit as part of everyday compliance (overview).
• Every online listing in Dubai needs a Trakheesi advertising permit. The same source gives fines of AED 50,000 per listing for a missing number; confirm the current schedule with RERA.
• In Abu Dhabi, brokers and sales are handled through the Abu Dhabi Real Estate Centre (ADREC); confirm the current licensing steps with it.

Register on goAML

Real estate brokers are designated non-financial businesses and professions, supervised by the Ministry of Economy. A Ministry circular, effective from July 2022, requires brokers to keep records and transaction data for at least five years and to report through the goAML platform (Ministry page). Reports named in the circular include suspicious transaction reports, funds freeze reports and partial name match reports, and a Real Estate Activity Report for certain freehold sales.

When a Real Estate Activity Report is due

A practice summary of Circular No. 5 of 2022 says a report is required when a freehold transaction is settled in physical cash of AED 55,000 or more (single or aggregated payments), or when any part of the price is paid in virtual assets or from funds converted from virtual assets (summary). The data to include covers the buyer and seller, nationalities and identification numbers, the date, the value and the amounts paid in cash or virtual assets. Agree with the buyer at the start that payment will be by bank transfer; this removes most of the reporting triggers.

Customer due diligence for a cross-border buyer

• For an individual, an Emirates ID or a passport copy; for a non-resident, the passport and proof of the address abroad.
• For a company, the trade licence, the articles, the register of beneficial owners and identification of the owners.
• The source of funds and, where the amount is large, the supporting evidence (a sale contract, salary and tax records, a bank statement showing the history).
• Whether the buyer or a close relative holds a prominent public position.
• A translation or legalisation of foreign documents where the authority asks.

Sanctions screening

Brokers are also covered by the UAE's targeted financial sanctions framework. Summaries of Cabinet Resolution 134 of 2025 describe a risk-based programme, registration with the Executive Office for Control and Non-Proliferation for notifications, screening of customers and beneficial owners on an ongoing basis, freezing assets and reporting matches through goAML, with a short deadline for notifying a freeze (overview). The same sources describe reports on high-risk countries and transactions. Penalties for non-compliance are reported to range widely, up to AED 5,000,000, under a 2025 federal decree-law; the amounts and the scope should be confirmed with a UAE lawyer.

Different clients, different files

• A UAE resident buying for the first time: Emirates ID, and the source of funds as for any buyer.
• A non-resident individual: passport, proof of the address abroad and, for larger amounts, the evidence behind the funds.
• A company: licence, articles, the register of beneficial owners and the identity of each owner.
• A buyer acting through a representative: the representative's identity, the power of attorney and a record of how it was verified.

High-risk countries and unusual requests

The circular also asks brokers to submit reports linked to high-risk countries and transactions through goAML, which means a broker should know which countries are on the current lists and apply extra care when a buyer, a payment route or a bank is connected to one. This is a compliance matter, not a reason to refuse every client from a given country: assess the individual case, document the reasoning and take advice. A request that the payment be split, routed through a third party or described differently in the contract is a reason to stop and ask a compliance adviser.

What to say to the buyer

• Explain the checks as standard. A buyer who understands them early is a smoother client.
• Tell the buyer that you cannot accept payment that would avoid the documentation, and that you may be required to report.
• Never advise on how to avoid a check. If a buyer asks, refer them to a lawyer.

A short file checklist

• Identity documents and, for companies, ownership documents.
• Source-of-funds evidence and the payment route agreed in writing.
• Screening result with the date and the lists used.
• The brokerage agreement and the advertising permit for the listing.
• Records kept for at least five years.

Working with D.H. Realting

D.H. Realting is a trilingual (Russian, English and Polish) overseas-property platform that introduces buyers, including expats living in Poland, the EU and elsewhere, to property abroad and supports the process. Agencies in the UAE that handle the deal locally and would like to be introduced to such buyers can contact us through our partners page. Terms are discussed individually.

This briefing is for information only and is not legal, tax or compliance advice. Rules change; confirm with a local lawyer and the competent authority before acting.