Dubai RERA Anti-Money Laundering for Brokers question: villa on Palm Jumeirah through

Dubai RERAAnti-Money Laundering for Brokers

A company registered abroad wants to buy a villa on Palm Jumeirah through your brokerage. Its share register shows two nominee shareholders, each holding 50% on behalf of Mr Karim, whose name appears nowhere else. Whom must you identify as beneficial owner?

A Mr Karim, the natural person who ultimately owns the whole company through the nominees
B No one; for a company buyer, verifying its licence and incorporation papers is enough
C The two nominee shareholders, as each is the registered holder of half of the shares
D The company's senior managing official, as no shareholder holds any shares in his own name

Show the answer and explanation

Answer: A. Mr Karim, the natural person who ultimately owns the whole company through the nominees

Customer due diligence covers the beneficial owner: the natural person who owns or controls 25% or more of a legal person, directly or indirectly (Cabinet Decision No. 109 of 2023 and the AML executive regulations, in force 12 Oct 2026). The nominees hold the shares for Mr Karim, so he ultimately owns 100% and is the beneficial owner; the nominees are only the registered holders. The senior managing official is a last-resort fallback used only when no natural person can be identified through ownership or control, which is not the case here. A nominee structure is also a risk indicator that justifies closer scrutiny. Source: Cabinet Decision No. 109 of 2023 (Real Beneficiary); Cabinet Decision No. 134 of 2025 (CDD) (in force 12 Oct 2026).

Common mistake

Stopping at the names on the share register instead of looking through the nominees to the person they act for.

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Study note: Anti-Money Laundering for Brokers (Federal Decree-Law 10 of 2025)Dubai RERApractice questions & mock exams

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Original study material mapped to the public exam domains; not a real test question.Independent. Not affiliated with DLD, RERA or DREI. Verify figures and rules against current guidance before relying on them.