Effective Date: 09/03/2025
ODAS STAR REAL ESTATE L.L.C is committed to conducting business in full compliance with applicable Anti-Money Laundering (AML), Counter-Terrorist Financing (CTF), and regulatory requirements within the United Arab Emirates.
As a real estate brokerage operating in Dubai, we recognize that real estate transactions may present elevated financial crime risks. We therefore maintain strict due diligence and compliance procedures.
1. Legal and Regulatory Framework
This policy is aligned with applicable UAE legislation, including but not limited to:
• Federal Decree-Law No. 20 of 2018 on Anti-Money Laundering
• Executive Regulations of AML/CTF
• UAE Cabinet Decisions and relevant guidance
• Applicable directives issued by competent authorities
The Company adheres to all regulatory reporting obligations.
2. Policy Objective
The objective of this AML & KYC Policy is to:
• Prevent money laundering and terrorist financing
• Detect suspicious activities
• Ensure transparency in real estate transactions
• Protect the integrity of the UAE real estate market
• Maintain regulatory compliance
3. Scope
This policy applies to:
• Property buyers and sellers
• Landlords and tenants
• Investors
• Corporate clients
• Introducers and intermediaries
• Business partners
It applies to all property sales, leasing transactions, consultancy services, and related activities.
4. Customer Due Diligence (CDD)
Before proceeding with transactions, the Company conducts Customer Due Diligence procedures.
For Individual Clients
We may request:
• Valid passport or Emirates ID
• Proof of residential address
• Visa copy (if applicable)
• Contact details verification
For Corporate Clients
We may request:
• Trade license
• Certificate of incorporation
• Memorandum and Articles of Association
• Shareholder register
• Identification of directors
• Identification of Ultimate Beneficial Owners (UBOs)
5. Source of Funds Verification
For certain transactions, particularly high-value property purchases, we may require:
• Bank statements
• Bank reference letters
• Proof of legitimate source of funds
• Transaction justification documentation
Failure to provide satisfactory documentation may result in refusal to proceed.
6. Risk-Based Approach
ODAS STAR REAL ESTATE L.L.C applies a risk-based approach when assessing clients and transactions.
Risk factors include:
• High-value cash transactions
• Complex ownership structures
• Politically Exposed Persons (PEPs)
• Clients from high-risk jurisdictions
• Third-party payment arrangements
Higher-risk clients may be subject to Enhanced Due Diligence (EDD).
7. Sanctions and Screening
All clients may be screened against applicable sanctions lists and international watchlists.
The Company will not engage in transactions involving sanctioned individuals, entities, or jurisdictions.
8. Transaction Monitoring
We monitor transactions for unusual patterns, including:
• Unexplained payment structures
• Multiple rapid transactions
• Use of intermediaries without transparency
• Requests to bypass standard procedures
Suspicious activity may trigger internal review.
9. Reporting Obligations
Where legally required, the Company may report suspicious transactions to competent UAE authorities.
Reporting obligations take precedence over commercial considerations.
10. Record Keeping
The Company maintains records of:
• Identification documents
• Transaction documentation
• Contracts
• Compliance screening records
Records are retained in accordance with applicable regulatory requirements.
11. Refusal or Termination of Business
ODAS STAR REAL ESTATE L.L.C reserves the right to refuse or terminate a business relationship where:
• Compliance documentation is insufficient
• False information is provided
• Regulatory risks are identified
• Suspicious activity is suspected
Business integrity and regulatory compliance take priority over commercial opportunity.
12. Internal Responsibility
Management ensures that compliance obligations are integrated into daily operations and transaction procedures.
Employees are expected to adhere strictly to AML and KYC requirements.
13. Policy Review
This policy is reviewed periodically to reflect regulatory updates and operational developments.
14. Contact for Compliance Matters
ODAS STAR REAL ESTATE L.L.C
Office No. 205–305, Al Khabeesi
Dubai, United Arab Emirates
Phone: +971 50 395 6811
Email: office@odasrealestate.com