Sanctions screening for real estate brokers and agents in the UAE

The Ministry of Economy and Tourism's 2026 guidance for real estate agents and brokers says firms must regularly screen customers and transactions against, at a minimum, the UAE terrorist lists and the UN Security Council consolidated list, and have procedures that stop any transaction with sanctioned persons.

Following the EOCN's targeted financial sanctions guidance, that means screening:

• buyers and sellers, before the deal and whenever the lists are updated;
• ultimate beneficial owners of any company or trust buying or selling;
• agents, representatives and anyone acting under a power of attorney; and
• former customers from the last five years when a new designation is published.

For a confirmed match, the transaction must be blocked immediately, no services provided, and a Confirmed Name Match Report (CNMR) filed in goAML within five business days. In the EOCN's real estate example, a broker who finds the prospective seller is a confirmed match blocks the sale and reports the property's type, value and location with the title deed and the seller's ID.

If you cannot tell whether it is the designated person, it is a partial name match: suspend or reject and file a Partial Name Match Report (PNMR). See how to file a CNMR or PNMR.

Separately from sanctions, the 2026 guidance requires brokers and agents to file a REAR for the purchase or sale of freehold property where:

• payment includes cash of AED 55,000 or more, in a single payment or several;
• any part of the price is paid in a virtual asset; or
• any part of the funds was converted from or to a virtual asset.

The REAR is not risk based: it is required even when due diligence is complete and there are no red flags. If a deal meets the REAR criteria and is also suspicious, both the REAR and the suspicious transaction report obligations apply.

Among the sector red flags, the guidance lists a client or known associate appearing on a targeted financial sanctions list or subject to embargoes issued by international organisations, such as the UAE terrorist list or the UN. Screening associates and beneficial owners, not just the named buyer, is how that gets caught. The full process is in our full guide to screening against the UAE Local Terrorist List and UN Consolidated List.