A buyer for a AED 9,000,000 penthouse in Downtown Dubai mentions that her brother is a serving minister in a foreign government. The brokerage already holds her passport and Emirates ID. What must it do before going further?
Politically exposed persons include foreign PEPs, and their family members and close associates are treated as PEPs for due diligence purposes. Under the 2025 executive regulations (Cabinet Decision No. 134 of 2025, in force 12 Oct 2026), enhanced due diligence includes senior management approval and establishing both the source of funds and the source of wealth. Being a PEP's relative is not suspicious in itself, so an STR is not automatic, and nothing bars brokers from acting for PEPs once the enhanced checks are done. Source: Cabinet Decision No. 134 of 2025 (EDD and PEPs) (in force 12 Oct 2026).
Applying the PEP rules to the office-holder only and forgetting family members and close associates.
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