Our compliance framework. Documented for partners.
Doro Technologies Ltd is a DIFC-registered software platform for UAE real estate transactions. This page sets out our compliance framework, controls, and governance arrangements for partners considering integration.
Software infrastructure. Not a payment provider.
What Doro does
- Provides a closed software platform for verified UAE real estate businesses
- Generates structured payment links anchored to verified property transactions
- Coordinates buyer identity verification, source-of-funds documentation, and audit trail
- Hands every regulated step (custody, conversion, settlement) to licensed PSP partners
- Maintains a full audit log of every action
What Doro does not do
- Custody, hold, convert, or transmit funds
- Make the regulated approval decision on a transaction
- Operate as a payment provider, MSB, or VASP
- Hold itself out as a regulated financial institution
- Make compliance decisions that override licensed counterparties
Doro is registered in the DIFC as a software house under licence CL12687. Doro is not a DFSA Authorised Firm and does not perform DFSA-regulated activities.
Two independent layers of control
Doro and the licensed PSP partner play different roles in the decision chain. Understanding the asymmetry is important to partners considering integration.
The PSP decides regulated activity
Whether a buyer's identity passes KYC, whether a wallet is clear of sanctions exposure, and whether funds may be released to the seller. These are decisions made by licensed parties under their own regulatory authorisations. Doro does not make these decisions and does not override them.
Doro decides platform participation
Doro reserves the right to decline to provide its service to any counterparty or transaction, including where the licensed PSP would proceed. A payment link created on Doro is not guaranteed to become live or active. If our internal controls surface concerns about the originating business, the documentation, the buyer profile, or any other factor, Doro will decline to issue or maintain the link.
Either layer can stop a transaction. Neither layer can compel the other to proceed.
Three gates before any transaction
Doro is not accessible to the general public. Every transaction passes through three layers of control.
Verified business
- Active UAE trade licence (DED, free zone, or DIFC)
- Registration with the Dubai Land Department
- Beneficial ownership verification (UBOs at or above 25%)
- Sanctions, PEP, and adverse media screening on each UBO and authorised signatory
- Agency bank account holder name verified against trade licence
- UAE PASS authentication for staff
- Active RERA broker registration for licensed agents
Verified transaction
- Sale and Purchase Agreement (SPA) required
- Title deed reference cross-checked against Dubai Land Department records
- Form F (DLD's official sale and purchase agreement) collected and retained
- Property valuation reviewed against transaction amount
- Seller identity matched against registered owner on title deed
- Beneficiary bank account holder name matched against seller of record
- Documents ingested through structured platform flows including verified WhatsApp ingestion
Verified approval
- Agency-level approval workflow before any payment link is issued
- Every approval logged with timestamp and identifier of the approver
- Multi-party commission splits documented with named recipients
- All payment links carry an immutable identifier and audit trail
Documented, reviewed, accountable
Doro maintains a documented compliance framework covering anti-money laundering, counter-terrorist financing, sanctions, data protection, and operational risk. The framework is implemented through internal policies, supporting procedures, automated controls, and outsourced specialist functions.
AML and CTF Policy
Full policy with documented Customer Due Diligence, Sanctions Screening, and SAR procedures. Reviewed annually and on material change.
Customer due diligence
Identity verification through specialist providers. Sanctions, PEP, and adverse media screening at onboarding and continuously.
Sanctions screening
UN, OFAC, EU, UK, and UAE local lists. Real-time matching at onboarding, transaction time, and on list updates.
Wallet and transaction screening
Blockchain analytics screening on every wallet, performed by licensed PSP partners.
Data protection
DIFC DPL compliance. Active ROPA, DPIA, breach notification, and data subject rights procedures.
Audit and record keeping
Immutable audit log on every action. Retention aligned to UAE AML and DIFC commercial law standards.
Controls built for property transactions
Real estate carries distinct AML risks. Documentary fraud, title manipulation, valuation games, and structured payments across multi-party splits. Generic fintech compliance does not cover these. Doro's platform-level controls are calibrated for the realities of UAE property transactions.
- 01
Title deed verification
Every title deed reference is cross-checked against Dubai Land Department records.
- 02
Form F collection
DLD's official sale and purchase agreement is collected and retained on every transaction.
- 03
Property valuation review
Transaction amount cross-checked against property valuation, with material variance triggering enhanced review.
- 04
Identity-to-deed matching
Seller identity verified against the registered owner on the title deed.
- 05
Beneficiary name matching
Bank account holder name matched against seller of record before settlement instruction is issued.
- 06
Multi-party commission discipline
Each commission split recipient documented and verified before payment.
- 07
Cross-deal pattern analysis
Properties, sellers, buyers, and agents monitored for unusual patterns across the platform's deal history.
Verifiable. Public. On the record.
Doro registrations
Operational partners
- Identity verification
- Wallet and transaction screening
- Cloud infrastructure
- Federated identity authentication
- Licensed PSP partners
Third-party security certifications such as ISO 27001 and SOC 2 are part of Doro's roadmap. We list them here when we hold them, not before.
What we can share
Doro maintains a complete set of compliance documentation, available to partners and counterparties under NDA. The full pack is provided on request and updated continuously as our framework evolves.
- AML and CTF Policy (full document)
- Customer Due Diligence Procedure
- Sanctions Screening Procedure
- Suspicious Activity Reporting Procedure
- Outsourcing and Vendor Management Policy
- Data Protection Compliance Programme and ROPA
- Sub-processor list with DPA status
- DIFC Commercial Licence and Certificate of Incumbency
- DIFC Data Protection Registration confirmation
- Sample audit log entry from a completed transaction (redacted)
Mohamed Kheir
Chief Executive Officer
For compliance, partner due diligence, and data protection inquiries.
mohamed@paywithdoro.com