Do DNFBPs have to identify the beneficial owner in the UAE?
Yes. Identifying and verifying the beneficial owner is a core part of customer due diligence for every DNFBP. The beneficial owner is the natural person who ultimately owns or controls the customer, and a DNFBP must look through corporate structures to identify that individual rather than stopping at the immediate legal entity.
As part of due diligence a DNFBP must verify the customer’s identity and the beneficial owner’s identity using reliable, independent sources, understand the ownership and control structure of legal persons and arrangements, and confirm that anyone acting for the customer is authorised to do so. Where the beneficial owner cannot be identified, or the information cannot be verified, the DNFBP should not proceed and should consider whether a suspicious transaction report is required. Accurate beneficial ownership information is also central to the UAE’s wider transparency obligations.
Legal Reference (UAE):
· Cabinet Resolution No. 134 of 2025 (Executive Regulations), Article 9 requires identification of the customer and the ownership and control structure.
· Federal Decree-Law No. 10 of 2025, Article 19 sets out customer due diligence and beneficial owner obligations.
For more details, consult the full text of Cabinet Resolution 134 of 2025 or seek guidance from your AML compliance officer.