This is Part 2 of our 4-part series explaining all 41 AML violations listed in Cabinet Resolution No. (71) of 2024 — a critical regulation that impacts all real estate companies and DNFBPs in the UAE.
In this blog, we focus on Violations 11–20, which cover:
- Customer identity verification
- Beneficial ownership
- Enhanced due diligence (EDD)
- Ongoing risk monitoring
- Third-party reliance mistakes
📌 **Legal Notice:**
This content is for general informational purposes only. While InfoAML strives to ensure accuracy, this blog does not constitute legal advice or replace formal consultation with a licensed compliance expert or lawyer in the UAE.
Violations 11–20 Explained
Violation 11
“Failure to verify - using documents or data from a reliable and independent source - of the customer identity and the real beneficiary or his deputy before or during the establishment of the business relationship or the account opening, or before conducting a transaction for a customer with whom he has no existing business relationship.”
Fine: AED 50,000 – 200,000
Tags: CDD, customer-verification, beneficial-owner
📌 You must verify both the client’s identity and the real beneficial owner using valid, independent documents — before starting business or processing a one-off deal.
Violation 12
“Failure to take necessary measures to understand the purpose, their nature, and nature of the business relationship of the customer and the structure of ownership as well as controlling the customer, or failure to obtain information related to such purpose whenever needed.”
Fine: AED 50,000 – 200,000
Tags: CDD, business-relationship, ownership-structure
📌 Real estate firms must ask: Why is the customer buying? Who owns the entity behind the deal? If you don't document this, you're at risk.
Violation 13
“Failure to take reasonable measures to address crime risks arising from customer and the business relationship to identify and validate the beneficial owner of legal persons and legal arrangements.”
Fine: AED 50,000 – 200,000
Tags: beneficial-owner, legal-entity-risk, ownership-verification
📌 You must identify and verify the actual human(s) behind legal companies, trusts, or other opaque structures.
Violation 14
“Failure of the facility to keep the information obtained through the execution of due diligence measures.”
Fine: AED 50,000 – 200,000
Tags: record-keeping, KYC-documents, CDD-history
📌 All CDD-related documents must be kept, organized, and available for review.
Violation 15
“Failure to take enhanced due diligence measures to manage high-risk when identified.”
Fine: AED 100,000 – 500,000
Tags: EDD, high-risk-clients, risk-response
📌 If a client is flagged as high-risk (e.g., due to geography, profile, or payment method), you must apply EDD. Not doing so is a serious breach.
Violation 16
“Failure to apply enhanced due diligence measures proportionate to the level of risk arising from business relationships or transactions with natural or legal person from the States designated by the committee as high-risk or with weak or deficient anti-money laundering and combating terrorism financing systems.”
Fine: AED 100,000 – 500,000
Tags: EDD, jurisdiction-risk, FATF-high-risk
📌 Transactions from or with individuals in FATF-high-risk countries require additional layers of scrutiny. You must document that you did so.
Violation 17
“Failure to apply countermeasures or other measures required by the supervisory authorities on their own or as specified by the committee with respect to high-risk States or those with weak or deficient anti-money laundering and combating terrorism financing systems.”
Fine: AED 100,000 – 500,000
Tags: countermeasures, EDD, sanctions
📌 Beyond EDD, you may be required to block, freeze, or apply other controls to clients from high-risk jurisdictions.
Violation 18
“Failure of the facility to set systems or take appropriate measures to manage risks or determine whether the customer or the beneficial owner is foreign or citizen, a politically exposed person or an individual who has previously held a prominent position in an international organization.”
Fine: AED 50,000 – 200,000
Tags: PEP-screening, risk-indicators, ownership-risk
📌 Your system must be able to identify whether a customer or owner is a PEP — and apply EDD accordingly.
Violation 19
“Failure of the facility to conduct ongoing auditing and monitoring of the continuing business relationship to ensure that documents, data, or information obtained under customer due diligence measures are up-to-date and relevant. This occurs through reviewing the registers and books, especially the registers and books of high-risk customer categories.”
Fine: AED 50,000 – 500,000
Tags: ongoing-monitoring, CDD-updates, risk-reviews
📌 AML monitoring isn’t a one-time effort. You must review and update customer profiles and documentation on a regular basis — especially for high-risk clients.
Violation 20
“Failure to abide by measures and procedures when relying on a third party to conduct customer due diligence measures.”
Fine: AED 50,000 – 200,000
Tags: third-party-risk, CDD-reliance, outsourced-KYC
📌 Even if you rely on a third-party to do CDD, you're still responsible. You must follow approved procedures and verify that the third party is compliant.
Final Thoughts – Part 2
Violations 11–20 deal heavily with customer due diligence, identity verification, beneficial ownership, and risk-based procedures. These are areas where real estate firms often face pressure to move quickly — but skipping steps can now cost hundreds of thousands of dirhams.
✅ Stay tuned for Part 3, where we’ll explain Violations 21–30: reporting lapses, suspicious transaction handling, and early-stage compliance officer duties.
Resources
Tags for this blog:
CDD, EDD, customer-verification, beneficial-owner, PEP-screening, risk-management, AML-UAE, cabinet-resolution-71, compliance-insights