Are Trust and Company Service Providers (TCSPs) considered DNFBPs in the UAE?
Yes. Trust and Company Service Providers are classified as DNFBPs under the UAE AML/CFT framework and must comply with the full set of preventive obligations. A TCSP is a business that provides services such as forming companies or other legal persons, acting as or arranging a director, secretary, or partner, providing a registered office or administrative address, acting as a trustee of an express trust, or acting as or arranging a nominee shareholder for another person.
Because these services can be misused to disguise ownership and control, TCSPs must identify and verify clients and beneficial owners, adopt a risk-based approach, monitor relationships, screen against sanctions lists, and report suspicions to the Financial Intelligence Unit. Mainland and commercial free zone TCSPs are supervised by the Ministry of Economy and Tourism.
Legal Reference (UAE):
· Cabinet Resolution No. 134 of 2025 (Executive Regulations), Article 3 — classifies trust and company service providers as DNFBPs.
· Federal Decree-Law No. 10 of 2025, Article 19 — sets the risk-based compliance obligations for DNFBPs.
For more details, consult the full text of Cabinet Resolution No. 134 of 2025 or seek guidance from your AML compliance officer.
AML and CFT requirements for trusts and company service providers in the UAE