Can a UAE accountant act for a client who uses a nominee shareholder or nominee director?
Yes, but only where the nominee arrangement is disclosed and the underlying beneficial owner is identified and verified. A nominee arrangement is not unlawful in itself. What is unacceptable is an arrangement that obscures who ultimately owns or controls the client.
A nominee director or nominee shareholder is required to notify the company of that capacity and disclose information about their status and the person on whose behalf they act. Companies in turn must obtain and retain beneficial owner information and updated nominee information, and must update it within fifteen working days of any change. Accountants must identify the beneficial owner of legal persons and take account of the risk arising from the customer and the relationship, which means the firm cannot simply record the nominee as the owner and close the file.
Where the nominee refuses to disclose the underlying principal, or the explanation offered does not hold together, the firm cannot complete due diligence and must decline or exit the relationship, and consider whether the refusal itself warrants a Suspicious Transaction Report. Providing false beneficial ownership information is separately criminalised.
Legal Reference (UAE):
· Cabinet Resolution No. 134 of 2025, Article 39 — nominee directors and shareholders must disclose their capacity and principal
· Federal Decree-Law No. 10 of 2025, Article 35 — penalties for providing false or misleading beneficial owner information
For more details, consult the full text of Cabinet Resolution No. 134 of 2025 or seek guidance from your AML compliance officer.