Are trust and company service providers DNFBPs in the UAE?
Yes. Trust and company service providers (TCSPs) are Designated Non-Financial Businesses and Professions under the UAE AML framework. TCSPs include businesses that form companies, act as or arrange for a person to act as a director, secretary or partner, provide a registered office or business address, act as or arrange a trustee of an express trust, or act as or arrange a nominee shareholder for another person.
Because these services can be misused to hide who really owns and controls a company, TCSPs are treated as key gatekeepers. They must run an enterprise-wide risk assessment, apply customer due diligence and enhanced due diligence, identify and verify beneficial owners, screen against sanctions and PEP lists, monitor relationships, keep records and report suspicious activity through goAML. MoET Circular No. 4 of 2021 remains the foundational sector circular for company service providers.
Legal Reference (UAE):
· Federal Decree-Law No. 10 of 2025, Article 19 - imposes preventive obligations on DNFBPs, including TCSPs.
· Cabinet Resolution No. 134 of 2025 (Executive Regulations) - defines TCSP activities within the DNFBP scope.
For more details, consult the full text of Federal Decree-Law No. 10 of 2025 or seek guidance from your AML compliance officer.
Yes. Trust and company service providers (TCSPs) are Designated Non-Financial Businesses and Professions under the UAE AML framework. TCSPs include businesses that form companies, act as or arrange for a person to act as a director, secretary or partner, provide a registered office or business address, act as or arrange a trustee of an express trust, or act as or arrange a nominee shareholder for another person.
Because these services can be misused to hide who really owns and controls a company, TCSPs are treated as key gatekeepers. They must run an enterprise-wide risk assessment, apply customer due diligence and enhanced due diligence, identify and verify beneficial owners, screen against sanctions and PEP lists, monitor relationships, keep records and report suspicious activity through goAML. MoET Circular No. 4 of 2021 remains the foundational sector circular for company service providers.
Legal Reference (UAE):
· Federal Decree-Law No. 10 of 2025, Article 19 - imposes preventive obligations on DNFBPs, including TCSPs.
· Cabinet Resolution No. 134 of 2025 (Executive Regulations) - defines TCSP activities within the DNFBP scope.
For more details, consult the full text of Federal Decree-Law No. 10 of 2025 or seek guidance from your AML compliance officer.