Do nominee directors have disclosure obligations under UAE AML law?
Yes. A manager or board member who acts as a nominee must inform the legal person of that nominee status and provide the required particulars within fifteen days of taking on the role. Anyone who was already a nominee when the beneficial owner rules were published had to notify the company within thirty days. The nominee must also report any change in their details, and the cessation of their nominee capacity, within fifteen days.
These duties exist so that the company’s registers reflect who is really acting on whose behalf, which supports accurate beneficial owner records. For a TCSP that arranges nominee directors, ensuring these disclosures are made and recorded is part of its own compliance duty. Failure to disclose a nominee arrangement is a red flag and can expose both the nominee and the provider to enforcement action.
Legal Reference (UAE):
· Cabinet Resolution No. 109 of 2023 (Real Beneficiary Procedures), Article 9 - requires nominee board members to disclose their status and changes within set deadlines.
· Federal Decree-Law No. 10 of 2025, Article 19(2)(c) - covers obligations of nominee directors and shareholders.
For more details, consult the full text of Cabinet Resolution No. 109 of 2023 or seek guidance from your AML compliance officer.