AML & KYC Policy

HEINZMANN CAPITAL REAL ESTATE L.L.C.(hereinafter "Heinzmann Partners", "we") is committed to preventing money laundering, terrorist financing and the misuse of the real-estate sector for the proceeds of crime. This policy summarises the procedures we apply to fulfil our obligations under UAE Federal Decree-Law No. 20 of 2018 on Anti-Money Laundering and Combating the Financing of Terrorism and Illegal Organisations, the implementing Cabinet Decision No. 10 of 2019, and the supervisory rules issued by the Real Estate Regulatory Agency (RERA) of the Dubai Land Department and the Central Bank of the United Arab Emirates.

Regulated entity:

This policy applies to every client relationship Heinzmann Partners enters into — whether the engagement concerns the acquisition, sale, brokerage, letting or management of real estate in the Emirate of Dubai. It applies equally to natural persons, legal entities, trusts and other arrangements. The policy is binding on all partners, employees and external advisers acting on behalf of the firm.

Before we accept a mandate, before we present an off-plan reservation, and before any funds related to a transaction pass through our systems, we conduct customer due diligence. We collect and verify:

• identity (full name, date of birth, nationality, residential address, valid government-issued photo ID, e.g. passport or Emirates ID);
• contact details (telephone, email);
• for corporate clients: trade-licence, certificate of incorporation, register extract, board / shareholder structure and authorised signatories;
• beneficial ownership down to every natural person who ultimately owns or controls 25% or more of a corporate client, including all controlling persons of trusts and similar structures;
• source of funds and, where required, source of wealth — supported by bank statements, sale contracts, salary certificates, audited accounts or comparable documentary evidence;
• purpose and intended nature of the transaction;
• politically-exposed-person (PEP) and sanctions screening against the UAE Local Terrorist List, the UN Consolidated List and the OFAC / EU sanctions lists.

For higher-risk relationships — including PEPs, clients from jurisdictions identified as high-risk by the FATF or the UAE National Anti-Money Laundering Committee, complex ownership structures or transactions that are unusually large relative to the client's profile — we apply enhanced due diligence. This may include additional documentation, independent verification of the source of funds, senior-management approval to commence or continue the relationship and tightened ongoing monitoring.

Client files are kept current throughout the relationship. We re-screen against sanctions and PEP lists on a periodic basis and whenever the client's circumstances change. Transactions and instructions are reviewed for consistency with the client's known profile. Where activity is unusual, complex or has no apparent economic purpose, we escalate internally and, where the legal threshold is met, file a Suspicious Transaction Report with the UAE Financial Intelligence Unit.

The processing of personal data described above is necessary for compliance with a legal obligation to which Heinzmann Partners is subject (Art. 6(1)(c) GDPR for EU data subjects; UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data for UAE-resident data subjects). Without this information we are legally prohibited from establishing or continuing a business relationship.

We retain identification documents, beneficial-ownership records, transaction files and supporting correspondence for a minimum of five (5) years following the end of the business relationship or the completion of the transaction, whichever is later. This retention period is mandated by Article 24 of Cabinet Decision No. 10 of 2019. Records may be retained for longer where required by another statutory obligation or where an investigation is open.

We do not share client KYC information with third parties for commercial purposes. We disclose information only:

• to UAE competent authorities (Financial Intelligence Unit, RERA, Central Bank of the UAE, Ministry of Economy, public prosecutor, courts) where required by law or by a binding order;
• to our regulated banking partners as far as necessary to execute a transaction on the client's instructions;
• to external auditors and legal counsel bound by professional secrecy;
• to correspondent regulators in another jurisdiction where a treaty or memorandum of understanding requires it.

Subject to the limits imposed by our anti-money-laundering obligations, you have the right to access the personal data we hold about you, to request the correction of inaccurate data, and to be informed in general terms about how your data is processed. Where statutory retention periods apply (see § 7), we cannot delete records before those periods expire, even on request. To exercise your rights, please use the contact channel listed in § 11.

UAE law prohibits informing a client or third party that a Suspicious Transaction Report has been or will be filed. Where we cannot proceed with a transaction for compliance reasons, we may therefore decline the mandate without providing a detailed explanation. We appreciate our clients' understanding that this restraint is itself a legal obligation.

For questions about this policy, the data we have collected, or to flag a concern in good faith, please write to:

We review this policy at least annually and whenever the underlying legal or supervisory framework changes materially. The currently applicable version is the one published on this page under the "Effective from" date above.